ML20055H638

Insp Rept 70-1151/90-05 on 900604-08.No Violations or Deviations Noted.Major Areas Inspected:Mgt Organization & Controls,Nuclear Criticality Safety,Operations Review,Maint & Surveillance Testing & Part 21 Reportable Items

ML20055H638
Person / Time
Site:	Westinghouse
Issue date:	07/12/1990
From:	Kasnicki D, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20055H636	List: ML20055H635 ML20055H638
References
70-1151-90-05, 70-1151-90-5, IEIN-90-027, IEIN-90-27, NUDOCS 9007270112
Download: ML20055H638 (9)

Text

{{#Wiki_filter:, } e ~- s s Mphte UNITED sTOTES s b' o NUCLEAR REGULATORY COMMISSION i /. f* REGION H - , h. 101 MARIET1 A STREET.N.W. I t ATLANT A. GEORGt A 30323 %,.... + / j Report No.: 70-1151/90-05 e-Licensee: Westinghouse Electric Corporation Commercial Nuclear Fuel Division Columbia, SC 29250 F Docket No.: 70-1151 License No.: SNM-1107 Facility Name: Westinghouse Electric Corporstion Inspection Conducted: June 4-8, 1990 Inspector: kh 7 ) 96 ~ 6.$Kasnicki,FuelFacilitiesInspector Aste' Signed , Accompanying Personnel: E. McApline, Chief, Radiation Safety Projects Section, NRC Region II Suffin, NRC H war j$ /'$6tm / r du' /}l- ) / f Approvedby:[. ,J M A'1 pine, Chief Date Signed Radiation Safety Projects Section Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection' was conducted in the areas of management organization and controls, nuclear criticality safety, operations review, maintenance and surveillance testing,10 CFR Part 21 reportable items, fcilowup regarding. one NRC information notice, and followup regarding two Inspector l Followup Items (IFI). Results: ~ In.- the areas inspected, violations or deviations were not identified. The licensee had identified no 10 CFR 21 reportable items, and had received the NRC information notice in question. Followup on a shipping problem which Westinghouse had previously identified to the NRC resulted in a Licensee Identified Violation (LIV). 9007270112 900712 PDR ADOCK 07001151 C FDC

7i 1 ,a Y h REPORT DETAILS 1. Persons Contacted Licensee Employees

• D. Goldback, Jr., Manager, Waste Recovery and Disposal
• W. Goodwin, Manager, Regulatory Affairs J. Hooper, Regulatory Engineer
• E. Keelen, Manager, Manufacturing

'R. Koga, Plant Manager 't

• R. Montgomery, Senior Regulatory Engineer

' E. Reitler, Manager, Regulatory Engineering T. Shannon, Regulatory Af f airs Technician

• R. Williams, Regulatory Aff airs Technical Coordinator i
• Attended Exit Interview 2.

Regulatory Compliance and Safety Policy Committees (88005, 88015, 88020) [ . Paragraph 3.1.2.5 and 3.1.2.6 of the-license application establish the Regulatory Compliance Committee (RCC) and the Safety Policy Committee, respectively, and outline specific requirements associated therewith. The v RCC. is defined to be that organizational component of the licensed activity responsible for overall coordination of licensing, compliance, regulatory and radiation protection matters, and for developing policies and procedures relating to the use and storage of special' nuclear materials. Special responsibilities are' defined to include:

1) review and assessment of the ALARA programs; 2) review and assessment of the SNM control, accountability and safeguards. programs; 3) review and assessment of occupational internal and external radiation exposures, radioactive material releases to unrestricted areas, and unusual occurrences;

4) review of noncompliance items and assurance of implementation of corrective action; and, 5)Lserving as the 10 CFR 21 Safety Review Committee for the Columbia Plant.

The Regulatory Compliance Committee is required to be chaired by a - qualified individual selected by the Plant Manager, and its. membership consists of the Manager of the Radiation Protection Component and at least three other-management personnel who are qualified to evaluate plant operations from the ALARA standpoint. The ccmmittee is required to convene at least quarterly on a routine basis, following any major radiation incidents, and when otherwise warranted by circumstances. The committee's findings, conclusions, and recommendations are required to be reported directly to the Plant Manager following each meeting. Appro-priate action is required to be taken, as required, to maintain and demonstrate compliance with the ALARA concept. i

2 The Safety Policy Committee is defined as a management advisory group to R . assure that operations are conducted in a manner to provide employees maximum possible protection from injury. In addition, the Committee is required - to ensure that sealth hazard concerns are adequately addressed. Each appropriate sta ff function is required to be represented on the Committee. 3 While discussing the functions of these two Committees, a Westinghouse representative indicated that the RCC also serves as the Safety Policy Committee. The inspector reviewed the C C meeting minutes dated March 23, 1990 and May 3,1990 and determined that the Committee was meeting as required. No violations or deviations were identified. 3. Internal Nuclear Criticality Safety Audits (88005, 88015, 88020) Paragraph 3.1.4.3 of the license aoplication requires radiation protection, nuclear criticality safety and SNM safeguards audits to be performed in accordance with a written plan at least monthly during operations. These audits are required to be performed by a Radiation Protection Component representative who 1s required to be accompanied by at least one cognizant line manager or his designee from each area under inspection. Any observed violations, the rquired corrective actions, assigned responsibilities, and completion dates are required to be documented in an inspection report. These inspection reports are required to be transmitted to the Plant Manager, Manuf actering management, and responsible managers of other areas inspected. The Radiation Protection Component is required to. provide followup to ensute that corrective actions are taken as required. Audit findings and recommendations are required to be reviewed to determine whether there are any undesirable trends, with results of these trend analyses documented in the Al. ARA Reports. Additionally, paragraph 3.1.4.2 of the license application requires Radiation Protection Component personnel on duty to conduct continuing inspections of nuclear criticality safety and radiation protection requirements in the course of their normal activities and in accordance with written guidance. Observed items are required to be immediately reported to the cognizant shift supervisor. Repeated or continuing items are required to be reported to the Manager of the Radiation Protection Component, who in turn is required to report them to higher levels of the line management for appropriate corrective action. The inspector reviewed monthly nuclear criticality safety audit documen-tation for January through May 1990. Two criticality safety findings were noted and they appeared to be addressed and resolved in a timely manner. No violations or deviations were identified. 4

[ .) a 3 i 4. Health Physics Manual (88005, 88020) i Paragraph 3.1.2.3(8) of the license application requires the Radiation Protection Component to be responsible for the maintenance of a site Health ~ Physics Manual. The Westinghouse CNFD site Health Physics manual is entitled " Regulatory Operations - Operating Procedures." This manual consists of procedures which address work that is done by the Health Physics Operations function. Upon reviewing the manual, the inspector noted that the procedures addressed equipment use and calibration, dosimetry, bioassays, surveys, release requirements, respiratory equip-ment, and environmental surveys. The inspector also noted that this manual had been reorganized to improve the categorization of the various L health physics procedures. No violations or deviations were identified. 5. 10 CFR 21 Reporting of Detects and Noncompliance (36100) 10 CFR 21 requires the lienesee to report certain problems' to the NRC such as defects and noncompliance which could create a substantial safety hazard. The inspector discussed this requirement with Westinghouse representatives who indicated that their program had not identified any reportable items. No violations or deviations were identified. 6. Modifications of UF. Heating System (88020, 88025, 92701) Westinghouse had previously established a task group to review the UF. cylinder heating and vaporization system. The group had developed some modifications (cylinder pressure sensors and steam interlocks) and was considering further modifications. These efforts were described as a study of the system which would be completed in phases. Through discussions with a Westinghouse representative, the inspector determined that all but one of the planned modifications have been implemented and that the installation of the last one, pressure sensors, is targeted for the end of this year..The inspector stated that, while this project is still' ongoing, efforts to initiate and follow through with the project appear to be complete and t.erefore the IFI previously identified concerning this item (IFI 88-11-03) would be closed. Further progress will be reviewed during subsequent routine inspections. No violations or deviations were identified. 7. Followup on NRC Information Notice 90-27: Clarification of Recent Revisions to the Regulatory Requirements for Packaging Uranium Hexaflouride (UF.) for Transportation (88005, 92701) l The inspector verified, through discussions with Westinghouse repre-sentatives, that they had received this information notice. Discussion j did not lead to fur.her questions. I

n 4 I l-No violations or deviations were identified. 1 1 8. Active Engineering Controls (Instrumentation) '4 (88015,88020,88025,92706) i The inspector discussed instrumented active engineering controls (AECs) with Westinghouse representatives. In addition to discussing tne general characteristics of AECS at the Columbia plant, the context of the discussion centered around the perception that AECs are only as good as the administrative controls which ket: them operable. The inspector l stated that AECs would be investigatea in more detail during subsequent inspections. No violations or deviations were identified. 9. Interviews with Operations Personnel (88015, 88020, 92706) The inspector conducted interviews with operators to ascertain the scope of their knowledge regarding the specific four nuclear safety requirements that are applicable to their jobs and their basic understanding of the subject of: nuclear criticality. These discussions indicated that they were familiar with their job-specific nuclear safety requirements and knew where to find operating procedures which contain these requirements. While familiarity and compliance with these requirements is essential, these discussions also indicated that these operators lacked an elementary, fundamental understanding of what nuclear criticality is and factors which affect reactivity, e.g., moderation. The inspector relayed these observations to Westinghouse management and stated that while knowledge of and compliance with rules is all that is required, a better understanding of the fundamentals would likely enhance compliance with rules and safety. Westinghouse representatives concurred. and indicated that they would consider these observations during their routine reviews of training plans. No violations or deviations were identified.

10. Area Specific Fire Emergency Plans (88005, 88020, 92701)

The inspector discussed the status of the development of area specific fire fighting pre plans with a Westinghouse representative. Discussion indicated that the development of this manual is virtually complete with final refinements being made prior to issuing controlled copies. While the development of this manual appears essentially complete, IFI 90-02-01 remains open pending review by an NRC fire protection inspector. No violations or deviations were identified.

r q 3 .I r 11. Facility Tour (88005, 88015, 88020) The inspector toured the entire production facility. The areas of interest were nuclear criticality safety limits and general nuclear criticality control procedures and criteria. Paragraph 2.3.1.9 of the license application requires that fuel be stored subject to postings, floor markings, or physical constraint. Paragraph 3.1.4.1 requires that operating procedures be available to personnel. Paragraph 2.3.1.1 of the license application requires that written procedures describing general. nuclear criticality control requireme ts shall be maintained in the Regulatory Affairs Procedures Manual by the Radiation Protection Component. Copies of. this manual are to be maintained by the line supervision in each functional area and the procedures contained therein i are to be communicated to affected personnel. Operations are required to be conducted in accordance with these procedures to ensure compliance with NRC regulations and license conditions. Paragraph 2.3.1.2 requires that a process er operation may be considered safe with respect to nuclear criticality if it requires at least two unlikely and unrelated accidents or errors to occur concurrently to cause a criticality accident. Paragraph 2.3.1.3 requires that materials of unknown enrichment shall be i handled as if it were at the maximum enrichment credible under the circumstances, Paragraph 2.3.1.5 requires that all transfers of enriched uranium oxides from geometry-controlled equipment or containers to moderation-controlled equipment or containers shall require moisture analyses prior to the transfers, c During a tour of the facility, the inspector determined that the licensee was complying with the above requirements. No violations or deviations were identified. 12. Instrument Calibrations (88015, 88020, 88025) Paragraph 3.2.1.2(2) of the license application requires that the criticality detection and alarm system be checked for proper functioning at itast every six months. Paragraph 3.2.1.2(9) requires that condu:tivity instruments in the vaporizer system be calibrated quarterly. The inspector reviewed records of these required calibrations and decermined that the licensee was in compliance with the requirements. No violations or deviations were identified, i -13. Criticality Safety Analyses (88015) L Paragraph 2.3.1.8 requires that the records of nuclear criticality safety + analyses shall include a f1cer plan of the SNM process and fixed storage areas showing the spacing requirements imposed to control neutron 1 ~ u b g 7

) 6 interaction except for pntable storage devices and shipping containers j which have been analyzed vor such storage, and have established spacing requirements to control i t.i. racti on. Paragraph 2.3.2(4) requires that, I when validated KENO computer codes are used to evaluate the Keff of individual isolated suberits, the following criteria shall apply: 1) the computer Keff plus bias (from validation) plus 2 sigma shall not exceed 0.95, and, 2) moderation control and neutron reflection assumptions shall include conditions expected to be encountered during both routine operations and credible accident situations. Paragraph 2.3.2(8) requires that suberits composed of fuel assemblies shall be limited by reactivity. The computed Keff, including allowances for computational error, shall not exceed 0.95. These computations shall be performed by individuals with qualifications contained in Subparagraph 3.3.7 or 3.3.8. The results of these computations shall be independently reviewed within the department performing _ the calculations and approved by the department manager before being transmitted to the NFD Manufacturing Department, i A random sample of the criticality safety analyses performed prior to and since the last inspection were reviewed and discussed with the Westinghouse representative. The inspector determined that the analyses were adequate. No violations or deviations were identified. 14. Shipping and Transportation: Licensee Identified Violation (LIV) 88005, 88015, 88020, 92701) At approximately 4:00 p.m. on March 29, 1990, the Region II office i received a telephone notification from Westinghouse, Columbia, regarding i an apparent shipping and transportation violation involving a " Limited Quantity" (less than 15g U-235) shipment. The shipment actually contained 2299 of low enriched U-235. The shipment was made on March 22, 1990, from Westinghouse, Columbia, to another Westinghouse facility in Madison, PA (Waltz Mill site), where it was received on March 23, 1990. The receiver, upon opening the package on March 27, 1990, visually identified a discrepancy between the physical characteristics of the material received versus the material anticipated and immediately notified Westinghnuse, Columbia. Following discussions of the incident, Westingnouse, Columbia sent two representatives to the Waltz Mill site on March 29, 1990 to investigate. They determined that the shipment contained more than a " Limited Quantity". Westinghouse's investigation of the root causes of this incident determined that the material in question, as per internal procedure, should not have been placed into a 55 gallon drum (non-favorable geometry container). Subsequent errors in initially assaying this drum, segregating the drum from other materials, and later visually characterizing the material and re-assaying the drum based on that visual characterization all led to this material being improperly labeled, marked

hY y i and packaged for shipment. Corrective actions resulting from their investigation included the revision and reorganization of applicable procedures, training to these procedures changes, and a review of all procedures related to packaging, inspecting and. shipping low-Level Radioactive Waste, Columbia had suspended all. low level shipments pending the results of their investigation and implementation of corrective actions. The inspector and accompanying Region II management reviewed this entire incident, including shipping documentat on and the licensee's reaction to the problem, and concluded that corrective actions appeared adequate. Further, Westinghouses' handling of this incident and other circumstances associated with it characterize it as a Licensee Identified Violation (LIV 90-05-01). This licensee identified violation is not being cited because criteria specified in Section V. G. 1 of the NRC' Enforcement Policy were satisfied. 15. Exit Interview The inspection scope and results were summarized on June 8,1990 with those persons indicated in paragraph 1. The inspector described the' areas-inspected and_ discuned in detail the inspection results. Although reviewed during this inspection, proprietary information is not contained in this report. Dissenting comments were not received from the licensee. I 1

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