ML20045H585
| ML20045H585 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 07/12/1993 |
| From: | Fici J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9307210011 | |
| Download: ML20045H585 (8) | |
Text
.
7_.s l
i
)
\\
i
\\v/
Westinghouse Commercial Nuclear Drawer R Electric Corporation Fuel Division Cggj"/jgcawa mso July 12, 1993 U.S.
NUCLEAR REGULATORY COMMISSION ATTN:
Documeat Control Desk Washington, DC 20555 Gentlemen:
SUBJECT:
REPLY TO A NOTICE OF VIOLATION RE FERENCE :
REPORT NO:
70-1151/93-03 Pursuant to the provisions delineated in Section 2.201 of the NRC's
" Rules of Practice", Part 2, Title 10, Code of Federal Regulations, Westinghouse herein provides, in APPENDIX A, formal response to your letter of June 4, 1993, regarding inspections of the Columbia Fuel Fabrication Facility conducted during the periods of April 19-23, 1993 and May 3-7, 1993.
In accordance with a telecon agreement between our Mr. Charles Sanders and Mr. Edward McAlpine of your Region II Office, on June 15, 1993, the response to the subject Notice of Violation has been delayed to July 12, 1993 -- to accommodate our annual Physical Inventory Of Special Nuclear Material at the Columbia Facility.
Should you have any questions or require additional information, please telephone me at (803)-776-2610.
I hereby af firm that the statements made in this response are true and correct to the best of my knowledge and belief.
Sincerely, WESTINGHOUSE ELECTRIC CORPORATION m f Q - Q l m :s A.Fici James A.
Fici, Planc Manager Columbia Fuel Fabrication Facility Itttachments:
APPENDIX A CC:
U.S.
NUCLEAR REGULATORY COMMISSION REGIONAL ADMINISTRATOR 101 MARIETTA STREET, N.W.
ATLANTA, GA 30323 9307210011 930712
[h 7
PDR ADOCK 07001151 C
PDR i
a l
The Htshnghouse CommercialNuclearfue/Dmpon - IMnnerofthe 1988Malcolin Baldnpe Nattoria/Oualih' Award
'O 4
70-1151/93-03 July 12, 1993 APPENDIX A WESTINGHOUSE RESPONSE TO THE ITEMS OF NONCOMPLIANCE IDENTIFIED IN THE NRC NOTICE OF VIOLATION A.
VIOLATION A:
With respect to the observation
- that, implemented controls associated with transfers of enriched uranium o:: ides from geometry controlled polypaks to a non-f avorable geometry blender were not suf ficient to comply with the double contingency principle in that only one adequate nuclear criticality safety barrier was implemented; and, This single barrier (associated with required moisture analysis) failed when on or about October 23,
- 1992, enriched U 0, from 3
geometry controlled polypaks was introduced into the non-f avorable geometry blender; and, On or about April 8, 1993, enriched UO from geometry controlled 2
polypaks was administrative 1y released to be introduced into the non-favorable geometry blender without the required moisture analyses being performed prior to the transfer --
The following information is provided:
A.1 The observation is acknowledged as stated in the Notice of Violation.
A.2 The reasons for the violation were:
Dependence on process controls to produce dry material instead of sufficient controls to both:
(1) prevent material without the required moisture analyses from being brought into moderation control areas; and, (2) to prevent its subsequent introduction into non-favorable geometry containers.
A.3 Immediate action to correct the observation, and results achieved, included:
A multi-disciplined team was established to perform a detailed evaluation of material transfer from f avorable geometry (FG) polypacks to non-f avorable geometry (NPG) containers. Af ter a
"i 4
comprehensive review, an enhanced system was developed and implemented to provide adequate double contingency protection for such transfers.
A detailed description of the system follows:
Enriched uranium oxides are produced on a routine basis at various locations within the facility.
Historically, these operations have been shown to consistently produce materials very low in moisture content.
A comprehensive dual sample-analysis-verification (SAV) program has been implemented to assure that the oxides produced are low in moisture content; and, are clearly identified as being acceptable for transfer to a NFG container.
This provides the basis of double contingency protection for such transfers, as follows:
(1) A composite sample is prepared that represents a batch of material.
The sample is composed of material taken from each polypack (i.e., a 100% composite).
The sample is submitted to the analytical laboratory for moisture analysis.
Operations personnel review the
- analysis, and if it
.is acceptable (moisture <= 0. 3%), then a unique marker is applied to each polypack container within the batch.
(If unacceptable results are identified, the containers are not marked, and the material is held for administrative disposition.)
(2)
Subsequently, _ Quality Control (QC) personnel independently i
collect an additional random sample from each batch of material with a good first moisture analysis.
A total count of containers for the batch is verified, the randomly selected 4
polypacks are identified for second moisture analysis; and, each selected polypack undergoes a weight verification check.
The material collected from selected containers is analyzed for moisture content.
(If the batch quantity count verification fails; or, if the randomly selected containers cannot be located, or fail to pass the weight verification check, the entire batch of material is subjected to a 100%
composite resample analysis for moisture. )
The laboratory enters the result of the second moisture analysis into the computer system, and the computer evaluates the analysis to determine if it is <= 0.3% moisture.
In addition, a check is performed to determine if the first and second moisture analyses agree within a predetermined range.
(If the second analysis is >
0.3%
- mpisture, the material is held for administrative disposition.
If the range check fails, the entire batch of material is subjected to a 100% composite resample analysis for mo$sture.)
QC personnel review the i
second analysis and if it acceptable, then a second unique marker is applied to each polypack container within the batch.
i When the acceptable material is to be used in blending l
operations, a blend is created by operations personnel, and is taken to a staging area for verification of moisture analyses prior to being transferred into a moderation control area.
(1) A staging area operator performs a visual inspection on 1
I
each polypack, and verifies that it has both moisture analysis markers applied.
Additionally, a crosscheck 'on container identification numbers is performed to verify that the~ correct polypacks have been collected.
The operator then signs the paperwork accompanying the
- material, to document.this verification operation.
(2) A duplicate marker /crosscheck.
verification is then performed on the same material by. QC personnel.
In addition, the presence of the signoff.of the-outside operator is verified, and the QC inspector signs the paperwork to document the duplicate verification operation.
(3) Finally, a material mover verifies that the paperwork for the material has been properly documented, before moving the material into the moderation control area.
This " Staging Area Administrative Barrier" provides the first line of defense for double contingency protection.
Inside the moderation control
- area, verifications are repeated.
(1) A moderation control area operator verifies that the paperwork for the material has been properly documented.
(2)
Additionally, a
visual inspection is performed on each polypack, to verify that each has both moi,sture analysis markers applied.
(3) Further, a computer transaction is performed against each container to verify its identity before its material is allowed to be transferred into a
non-favorable geometry container.
This "MODCON Area Administrative Barrier" provides the second line of defense for double contingency protection.
These multiple verifications function to. provide double contingency protection to preclude the introduction of unacceptable enriched oxides into non-favorable geometry containers, _ independent of the process that producea the material.
The computer software changes required to. fully implement this program are in progress.
A4 Actions planned, to prevent recurrence of events of the type observed, include:
Westinghouse believes that the program described above includes sufficient controls to prevent recurrence of events of the type observed.
An evaluation of other options, that might be used to supplement or replace portions of the described system is in progress.
A.5 Full compliance will be achieved by July 19, 1993.
.r B.-
VIOLATION B:
With respect to the' observation that, on or about March 9,1993, an-untumbled, unhomogeneous samp e was submitted'to'the laboratory for analysis which resulted in an analytical result which was biased --
The following information is provided:
B.1 The observation is acknowledged as stated in the Notice of Violation.
B.2 The reasons for the violation were:
Failure of an operator to remove the last ' partial' polypack of cleanout material from the fitzmill when maintenance activities had been completed.
It was-inadvertently included with the current process product-material and sampled as part of the conversion line batch.
B.3 Immediate action to correct the observation, and results achieved, included:
Once the sample analysis for this material was available and identified to be high in moisture,. an investigation was undertaken.
Each individual polypack.within the batch was sampled and analyzed for moisture, and it was determined that the only material with unacceptable moisture was the pack with the cleanout material. This material was subsequently removed from the product batch for scrap recovery.
B.4 Actions planned, to prevent recurrence of events of the type observed, include:
In addition to taking the actions described'in section A of this
- Appendix, a comprehensive evaluation of the total sampling, analysis, and verification program was initiated, and has resulted in enhancement of the methods utilized for determining the moisture content of oxides in polypacks --
including laboratory mixing for homogenization.
In addition, applicable operating procedures were reviewed and are being updated to provide distinct instructions for the proper handling of materials generated through maintenance activities.
These procedure revisions are expected to be completed by July 30, 1993.
B.5 Westinghouse is currently in full compliance.
C.
VIOLATION C:
With respect to the observation that, on February 16, 1993 Westinghouse discovered that moisture analyzers had been removed from check hoppers in the IDR conversion system at a point in time either prior to or soon after process startup in March 1985 --
4 The following information is provided:
C.1 The observation is acknowledged as stated in the Notice of Violation.
C.2 The reasons for the violation were:
Insufficient configuration controls were in place to identify the inappropriate removal of moisture analyzers from the IDR system.
C.3 Immediate action to correct the observation, and results achieved, included:
Replacement moisture analyzers were procured and installed in the IDR conversion system.
System testing and qualification are in progress and expected to be completed by October 1, 1993.
C.4 Actions planned, to prevent recurrence of events of the type observed, include:
A formal configuration control program has been implemented within the facility to preclude recurrence of this type of event.
C.5 Full compliance will be achieved by October 1, 1993.
D.
VIOLATION D:
With respect to the observation that, on April 21,
- 1993, four polypaks were noted inside the hood located by the Solvent Extraction Control Room, and three of the polypaks were stored within 6 to 8 inches of each other -- contrary to the criticality sign on the hood; and, On April 21, 1993, polypaks containing materials such as press cake, sludge, and torit (bag filter) fines were noted to be stored on a storage rack in the Solvent Extraction area -- which was not authorized by the posted criticality sign; and, On April 21, 1993, at approximately 11:00 a.m., three plastic bags l
containing dirty rags were noted on the floor in the general area of Conversion Line No.
5, across from the' Stratification Blender where repair work was being performed on a pellet press.
(One bag was laying beside a red 5-gallon scrap can, one bag was laying F
4
1 s
e-h approximately three feet from a red 5-gallon scrap can, and the j
third bag was near the pellet press).
At approximately 6:15 p.m.
that evening, two bags containing dirty rags and an unbagged dirty rag were laying on the floor next to a red 5 gallon scrap can and a wet, dirty mop head was laying on the floor approximately six feet away.
These items were in the same locations at approximately 7:15 p.m.
At approximately 8:15 a.m.
on April 22, 1993,, the two bags cor.taining dirty rags and the unbagged dirty rag were still laying on the floor against the red 5-gallon scrap can -- contrary to the procedure concerning handling scrap --
The following information is provided:
D.1 The observation is acknowledged as stated in the Notice of Violation.
D.2 The reasons for the violation were:
Ineffective operations training in the specific areas of criticality postings and floor spacing requirements.
In addition, some of the criticality postings and corresponding procedures were ambiguous.
D.3 Immediate action to correct the observation, and results achieved, included:
The items identified in this violation were immediately corrected af ter the inspector's observations were reported to Westinghouse personnel and the affected operations personnel received prompt supplemental training.
D.4 Actions planned, to prevent recurrence of events of the type observed, include:
Comprehensive training sessions were held with all Chemical Area operations personnel.
Specific topics covered were criticality awareness, floor storage spacing requirements, and strict adherence to criticality postings and operating procedures.
Teams were created to evaluate the methods of floor storage within the facility.
These teams have reported their findings and recommendations to management for review and implementation. The management review will be completed by August 15, 1993.
All criticality signs have been reviewed and revised as appropriate.
In addition, an enhanced criticality posting program has been developed, and results are expected to be in place by August 15, 1993.
.s d
The routine inspection of floor storage and criticality postings has been added as a specific line item in the monthly Regulatory Affairs inspection program.
In addition, area operations management and supervision will conduct random inspections of these areas for compliance.
~
D.5 Westinghouse is currently in full compliance.
e i
!