ML20056E411

Insp Rept 70-1257/93-09 on 930726-30.Violations Noted But Not Cited.Major Areas Inspected:Maint/Surveillance Testing, Radiation Protection,Criticality Safety/Operations Review, Environ/Waste Mgt & Followup on Open Items

ML20056E411
Person / Time
Site:	Framatome ANP Richland
Issue date:	08/08/1993
From:	Brewer K, Hooker C, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20056E409	List: ML20056E408 ML20056E411
References
70-1257-93-09, 70-1257-93-9, NUDOCS 9308240003
Download: ML20056E411 (12)

Text

f U.S. NUCLEAR REGULATORY COMMISSION REGION V

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Report No. 70-1257/93-09 Docket No. 70-1257 License No. SNM-1227 l

l Licensee:

Siemens Power Corporation 2101 Horn Rapids Road Richland, Washington 99352-0130 t

Facility Name: Siemens Power Corporation Inspection at: Richland, Washington Inspection Conducted: July 26-30, 1993 W

P# 93 i

Inspectors:

__C. A. Hooker, Fuel Facilities Inspector Da'te Signed AMMA rAAs K/ r6wer/Radi n pecialist Date digned Approved by:

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~._fw 88 3

[Jajm ( f. Rees6, 'Chrpf Date S'igned raciT4 ties Radiolog'ical Protection Branch l

Summary:

Areas Inspected: This was a unannounced routine inspection of maintenance / surveillance testing, radiation protection, criticality I

safety / operations review, environmental / waste management, and followup on open items.

Inspection procedures 30703, 88025, 83822, 88015, 88020, 88035, 88045, 92701, and 92702 were addressed.

Results: Within the scope of this inspection, two non-cited violations (NCVs) involving (1) the failure to conduct monthly safety checks (Section 2.0), and (2) failure to maintain operations within the specified mass control limit (Section 5.3) were identified.

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9308240003 930808 C

PDR ADOCK 07001257 hj C

PDR g:

DETAILS 1.0 Persons Contacted 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

• L. J. Maas, Manager, Regulatory Compliance

• J. B. Edgar, Staff Engineer, Licensing

• S. S. Koegler, Manager, Waste Management Engineering

• J. A. Shurts, Manager Materials and Scheduling

• B. F. Bently, Manager, Plant Operations (effective August 2,1993)

J. H. Phillips, General Supervisor, Chemical Operations

• T. C. Probasco, Safety Supervisor M. S. Stricker, Sr. Chemical Engineer C. D. Manning, Criticality Safety Specialist

• R.

K. Burklin. Health Physicist

• E. L. Foster, Supervisor, Radiological Safety G. Kasco, Sr. Engineering Assistant NRC Personnel

• J. H. Reese, Chief, Facilities Radiological Protection Branch, RV

• Denotes those attending the open exit interview on July 30, 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 singular use of the word

" inspector" indicates that only one inspector was involved in the specific area and the plural use indicates that more that one inspector shared involvement in the specific area.

2.0 Maintenance / Surveillance Testina (88025)

Previous inspections conducted during the past year have examined various aspects of the licensee's maintenance / surveillance program.

The inspection of this area was primarily focused on newly installed equipment.

The licensee's preventative maintenance (PM) and instrument repetitive maintenance (calibrations and equipment tests) consists of a commercially supplied computerized maintenance management system (PERMAC).

The PERMAC system is used to schedule, issue and track PM activities for maintaining plant equipment, facilities, systems and support activities. The PERMAC system lists about 1500 items for routine PM and about 1700 instrument repetitive maintenance (IRM) items.

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2 PM and IRM frequencies are based on either the manufactures and users recommendations and/or requirements of the License.

The system also provides maintenance history and on-hand spare parts for each item.

Procedures for PM's and IRM's adequately delineated personnel responsibilities and authorities for various sections of the licensee's programs.

During this inspection, the inspector reviewed records of calibrations and tests of selected IRMs/PMs for newly installed devices considered important to criticality and operational safety, which included; (1) slab hopper temperature monitoring and alarm systems; and (2) alarm and powder vacuum transfer trip systems for water and humidity sensing devices installed in the conversion Line 2 powder preparation hoods. The inspector noted that calibrations and functional tests were conducted using established calibration procedures.

Established frequencies for calibrations and functional tests appeared appropriate.

Appropriate procedures had been developed for performing the calibrations and functional tests for the new devices.

Monthly tests of safety equipment associated with the uranium hexafluoride (UF.) gas transfer system for Line 1 and Line 2 chemical conversion operations, which includes the emergency scrubbing systems, performed from July 1992 through July 1993 by Chemical Operations were also reviewed. The inspector made the following observations:

(1)

Safety Condition No. S-1 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 i

November 12, 1987, through April 29, 1993.

Section 2.5 " Operating Procedures, Standards and Guides," Part I of the 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.

Sections 4.0, " Primary Header Interlock," 5.0, " Secondary Header Interlock," 6.0, " Vaporization Room Scrubbers, of pror.edure P66,823, " Monthly Safety Interlock and Scrubber Testing Procedures," Rev. 6, dated August 19, 1992, of the Standard Operating Procedures Manual (EMF-22) require the associated tests to be conducted monthly or after an outage of more than one month.

(2)

Based on the examination of the monthly test data and discussions with operating personnel, the inspector concluded that the required tests for the Line 2 UF system had not been conducted for the month of May 1993. The inspector noted that records of the tests conducted in March, June, and July 1993 did not reveal any abnormal conditions that could result in adverse conditions related to plant operations or personnel safety.

Additionally, the failure to conduct the monthly tests appeared to be an isolated case.

Since this program was solely maintained by

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Chemical Operations, the Supervisor, Chemical Operations i

immediately made arrangements to place these tests on the licensee's PM system to assure that they would not be missed in the future.

Failure to perform the Monthly test was identified as a violation of Safety Condition No. S-1.

However, this violation will not be subject to enforcement action because the criteria in Section VII.B. of the Enforcement Policy were satisfied (NCV 70-1257/93-09-01).

The inspector reviewd the use of Cutting-Welding-Hot Work Permits.

During the normal work days, the maintenance supervisor or his designee approved the permits. During back-shift hours and weekends, the permits 4

j were approved by the Shift Supervisor of the area where the work was to be performed. Procedure ANF-P65,531, " Hot Work Procedure," Chapter 1, of the Safety Manual EMF-30, governed the use of the permit.

Although the inspector did not identify a situation where a permit was not used when required, a number of maintenance staff were unable to identify the procedure that specified the use of the permit. Additionally, the inspector noted that the " Weld" check box on " Work Orders" (W0s) was seldom marked to indicate that a permit was needed.

The inspector noted that the implementing engineering procedure for W0s used by the maintenance staff did not discuss the use of this permit. These observations were discussed with cognizant licensee representatives during the inspection and at the exit interview.

During facility tours no excessive oil or other liquids were observed to be leaking from equipment or systems. Ventilation systems appeared to be operating as expected in all areas toured.

Racks for storing SNM appeared to be intact and adequately maintained.

The licensee's program appeared adequate to accomplish their safety objectives. The licensee's maintenance and calibration program appearei to be well managed in accordance with current accepted nuclear industry standards. One NCV was identified.

3.0 Radiation Protection (83822)

The inspector examined the licensee's radiation protection program for any changes since the previous inspection (70-1257/93-01, February 4-11, 1993).

The inspection consisted of interviews with cognizant personnel, reviews of pertinent documents and procedures, and facility tours.

3.1 Chanaes The licensee had made substantial progress in instituting new Radiological Safety and Site Radiological Operating Procedures, which are intended to supersede the older XN-NF series procedures, since the previous inspection. At the time of the inspection, the licensee had issued the following procedures:

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4 EMF-1507, 2.2 - Operation and Quality Control of Tennelec Surface Barrier Counter, issued May 1, 1993.

EMF-1507, 2.6 - Portable Count-rate Meters with Pancake Type GM l

Probes, issued April 16, 1993.

EMF-1507, 3.2 - Routine Urine Sampling Program, issued May 1, 1993.

EMF-1507, 3.3 - Invivo Counting Program, issued May 1, 1993.

EMF-1507, 3.4 - Nasal Smears, issued March 3,1993.

EMF-1507, 3.5 - Unusual Incidents / Bioassay, issued May 1,1993.

EMF-1507, 5.1 - Routine Facility Radiation Level Surveys, issued March 8, 1993.

EMF-1507, 9.2 - Cleaning and Inspection of Respirators, issued March 4, 1993.

l EMF-1508, 1.1 - Preparation and Revision of Site Radiological Operating Procedures, issued June 15, 1993.

EMF-1508, 2.8 - Bioassay Program, issued May 1, 1993.

EMF-1508, 2.9 - Unusual Incidents with the Potential for Internal Radiation Dose, issued May 1, 1993.

EMF-30, Chapter 2, section 8.0 - Reporting of Incidents, issued March 26, 1993.

The procedures presented above were of adequate scope and depth to accomplish their intended objectives.

The licensee was approximately 30% complete in its effort to update Radiation Protection procedures.

3.2 New 10 CFR Part 20 Efforts The inspector noted the licensee's progress toward implementation of new 10 CFR Part 20 (new Part 20).on January 1, 1994.

The licensee had made noticeable progress in developing Radiological Safety Procedures related to new part 20 implementation, as. evidenced by the following:

EMF-1507, 10.1 - Posting Requirements, issued A.ne" 19, 1993 (effective January 1, 1994).

EMF-1507, 6.3 - Environmental TLD Program, Draft.

EMF-1507, 2.5 - Anderson Particle Size Analyzer, Draft.

The licensee was preparing to institute a program to characterize the particle size of work zone airborne uranium compounds.

To aid in this

5 effort, the licensee purchased five Anderson Particle Size Analyzers.

The inspector noted that the licensee had developed a plan for designing i

and implementing a computerized personnel work zone tracking system (Health Physics System). The licensee planned to complete worker training on the Health Physics System by November 23, 1993, and~have the system fully operational by January 3,1994.

The inspector regarded the licensee's progress as being timely, but noted that substantial work remained prior to implementation in January 1994.

3.3 Audits and Reports The inspector reviewed the licensee's ALARA report for the period January 1 to December 31, 1992, noting significant changes from past ALARA reports. The licensee instituted more comprehensive trending efforts with an increase in computerized data handling. Two year and five year data trends were presented, indicating ALARA program results and identifying areas requiring increased ALARA efforts.

The inspector noted that despite a five year trend of increased production activity, the licensee had a noticeable downward trend in the invivo and urine analysis levels of personnel in most work groups (i.e.

Conversion, Ceramics, Plant Support, etc.).

A noticeable increase in external personnel exposures was identified for nearly all site work groups. The licensee attributed the increase in external personnel exposure to the increased production activity over the same five year period. The inspector noted the correlation between external exposure and production activity to be in good agreement. The licensee considered the area of external personnel exposure for enhanced attention though external personnel exposures were significantly below regulatory limits.

The licensee's program appeared adequate to accomplish their. safety 1

objectives. The new procedures were noted as being a major improvement in the radiation safety program.

No violations or deviations were

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identified.

4.0 Environmental Protection / Waste Management (88045 and 88035)

The review of this area focused on the licensee's interaction with Washington State Department of Ecology (WD0E) regarding previous WD0E's concerns with characterization and designation of facility waste streams and effluent releases.

To aid in this effort, the licensee created the Waste Management Engineering Group (WME), as described in previous inspection reports. WME consists of a manager, three senior engineers, one engineer (level 2), and a clerk. The manager of WME reports directly to the Manager of Manufacturing Engineering. A draft waste management plan is being created by WME to assign and schedule tasks for handling existing wastes (i.e. non-radioactive hazardous, radioactive, and mixed wastes) and mirimizing the generation of future wastes.

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6 The inspector noted that the licensee appeared to be making progress in its efforts to manage its wastes and to prepare a part B (Dangerous Waste Permit) application for WDOE. The licensee has completed the first round of surface impoundment waste sampling and is prepari_ng to begin the second round of surface impoundment sampling.

5.0 Criticality / Operational Safety (88015 and 88020)

Inspection Report No. 70-1257/92-08, 93-02 and 05 describe previous inspection activities in this area. This inspection of these areas was primarily focused on observations made during facility tours and discussions with cognizant personnel.

The inspector toured selected facilities to observe current operations and criticality controls. The inspector observed no problems with posting of criticality control limits or criticality safety practices in l

the areas toured. Based on discussions with operators, the inspector verified that they were cognizant of the installation and purpose of newly installed safety devices (water sensors, humidity detectors and their associated alarms) in the powder preparation systems.

No violations or deviations were identified.

5.0 Followuo - Licensee Action on Previous Inspection Findina 5.1 Cited Violations (92702) t 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.

70-1257/93-03-01 (Closed) - Failure to Provide Certification Exams to Health & Safety Technicians Based on a review of training records, the inspector verified that the certification exams had been provided to the Health & Safety Technicians (H&STs) as stated in the licensee's letter dated July 6,1993, and the addition of a new procedure related to H&ST training was being adequately addressed.

70-1257/93-01-01 (Closed) - Failure to Calibrate Five Surface Barrier Detectors The inspector noted that an " Add Request" was submitted on February 10, 1993, to add the surface barrier detectors (SBDs) to the IRM system and to perform and document an energy spectrum calibration on a six month frequency. The inspector confirmed that two Maintenance Instrument procedures, Calibration Procedures No. 155 Revision 2, effective March 9, 1993 and No. 156 Revision 1, effective February 22, 1993, were issued which adequately addressed the energy spectrum calibration of the SBDs.

Based on a review of licensee procedures, calibration records and instrument calibration stickers, the inspector verified that an energy

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l spectrum calibration was performed on each of the SBDs on February 16, l

1993 and that the required calibration was being performed at the l

required frequency.

70-1257/93-03-05 (Closed) - Failure to Document and Maintain Transport Vehicle Survey Records The inspector verified that ue Radioactive Material Shipment Record (RSR) form had been revised on April 4,1993, to provide specific space for recording survey results of transport vehicles.

Based on a review of past shipment records since April 1993, the inspector noted that the licensee was effectively implementing their corrective actions.

The previous revision of the RSR form was removed from use and the H&STs were properly documenting survey results.

5.2 Non-Cited Violations (927021 l

70-1257/93-01-02 (Closed) - Failure to Post Entrances to Buildinas Containina Radioactive Materials The inspector verified the licensee's posting at the entrances to the uranium dioxide (UO,) Building, Specialty Fuels Building, and various other buildings at the facility. All entrances were adequately posted to inform workers of the radiological conditions within each area or building.

5.3 Inspector Followuo Items (92701) 70-1257/91-04-24 (Closed) - Health and Safety Technicians are not Proactive The inspctor noted several improvements to the Radiation Protection Program aimed at enhancing technician proactiveness:

(1)

Radiation Work Procedure (RWP) Manual (EMF-897) " Introduction",

Rev. 15, effective March 30, 1993, instituted an enhanced Radiological Observation tracking system. The new system required H&STs to identify, correct and log observations of radiation worker violations (i.e. not wearing gloves, no eye protection, not adhering to posting etc.). The observation log is audited monthly by the Radiation Protection Supervisor and a monthly summary report is pre:,ented to the supervisors of various work groups at i

the monthly Health and Safety Council meeting.

(2)

The introduction of the Radiological Safety "Mid-Shift" and "End of Shift" summary reports. The introduction of this program required the H&STs to complete the "Mid-Shift" and "End of Shift" summary reports every shift. To complete the summary reports, the H&STs would need to be aware of the work in progress, the radiological conditions which existed, and any incidents or abnormal events which occurred on their shift. The oncoming H&STs were required to review the previous shift's "Mid-Shift" and "End

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8 of Shift" summary reports prior to the start of work activities.

(3)

Another improvement noted was the requirement of the H&STs to complete an " Abnormal Event Report" for any incidents which occurred on their shift.

i The improvements discussed above established a means by which the l

licensee ensures that the H&ST staff are aware of the changing work environment in the plant and that the H&STs are in the field maintaining a proactive posture.

70-1257/91-04-19 (Closed) - Voarade Bioassay Procedures for Urine Samplina e

The in:pector verified that the licensee had effectively developed new procedures that adequately documented their urine sampling program.

Health Physics and Radiological Safety Procedure EMF-1507,3.1, " Quality 7

Control of Urine Sampling Program," dated January 4,1993, described an improved quality control program (spiked samples) to assure the accuracy of analysis provided by their contracted urinalysis laboratory.

Procedure EMF-1507,3.2, " Routine Urine Sampling Program," dated April 8, 1993, adequately addressed the licensee's urine sampling for transportable and non-transportable uranium compounds.

70-1257/93-03-06 (0 pen) - Review of the Licensee's Criticality Safety Analysis (CSA) Update Proaram The inspector noted that the licensee had completed Phase 1 (initial review and system grouping of existing CSAs) of their CSA update program by June 30, 1993, as delineated in the licensee's letter to the NRC, l

"Siemens Power Corporation (SPC) Criticality Safety Analysis Update Program," to the NRC dated December 30, 1992. This letter also described licensee's description of system categorization, and the tasks to be performed for each phase (1-3) of the CSA update program.

From 216 original old CSAs, the licensee had grouped them into 59 systems (combining of single equipment / component CSAs into one integrated process system CSA).

At the completion of Phase 1, the licensee had identified 4 category I, 28 category II, and 27 category III systems. Of the 4 category I systems, only one system (Solid Waste Uranium Recovery - Incinerator) that is shutdown remained in this classification. The other three systems (Line 1 Uranium Recovery, Line 1 Process Offgas, and Pellet Grind & Inspection) were reclassified as category 11 systems. The reclassification followed the licensee's verification that " recommended" controls specified in older CSAs and/or changes. in configuration were bounded by an updated CSA which adequately provided the' safety basis for l

the involved system. As a direct result of the reviews conducted during Phase 1, the licensee identified two conditions that met the reporting requirement of NRC Bulletin 91-01:

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(1)

June 9, 1993, Event Report No. 25632 - Line 1 Process Offgas (P0G)

Scrubber Separator Unit.

(2)

June 17, 1993, Event Report No. 25662 - Un-authorized Equipment Modification.

The CSA update program also partially contributed to the licensee's identification of the April 28, 1993, Incinerator Ash Buildup, Event Report No. 25458 discussed below.

The inspector examined four systems that had been reviewed by the licensee during Phase 1: (1) System 1.4 - Line 1 Uranium Recovery, (2)

System 1.6 - Line 1 Process Offgas, (3) System 1.8 - Line 2 ADO Process,.

and (4) System 1.9 - Line 2 Uranium Recovery.

The inspector did not identify any deficiencies or conditions that required reporting to the NRC that had not been identified by the licensee's review.

Regarding the licensee's completion of Phase 1 of the update program, the inspector noted that a significant licensee and contracted rescurces had been devoted to this program.

The reviews performed appeared to be comprehensive and goals achieved. Manegement's involvement and realization of the importance of the CSA update program was evidenced from documents reviewed and personnel interviews.

During the inspection, the inspector also noted that the licensee had initiated Phase 2 of the program. The inspector observed (in-plant) three individuals (two from Plant Engineering and one from Plant Operations) actively verifying and correcting as-built drawings for System 1.10, Line 2 ADU Conversion to Ceramic Grade U0 Powder.

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licensee was also evaluating the time and resources needed for continuing with this portion of Phase 2 for other systems to ensure timely completion. During discussions with these individuals, the inspector noted that they displayed a keen awareness of the importance of their task. The inspector also noted that management was keeping abreast of the program to assure its timely completion. The inspector noted no concerns related to the licensee's initiation of Phase 2 of the CSA update program.

70-1257/93-07-01 (Closed) Review licensee's Investication of the Solid j

Waste Uranium Recoverv (SWUR) Incinerator Overbatch - Event No. 25458 l

This item involved the need to review the licensee's investigation of the subject event, which was described in Inspection Report No. 70-1257/93-07. During this inspection (70-1257/93-09), the inspector reviewed and discussed the licensee's investigation report, "SWUR Overbatch Investigation," dated June 29, 1993.

This licensee identified problem was reported to the NRC Operations Officer on April 28, 1993, in accordance with the NRC Bulletin 91-01, reporting requirements.

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i Based on a review of sample results of the material cleaned from the incinerator and the analysis of the ash removed from the last burn run, the licensee determined that the safe mass limit for incinerator had been exceeded. The operating mass limit established for the incinerator i

was 793 grams U-235 based on uranium with an enrichment of 5.0 weight

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percent (wt.%) U-235, which is about 31.75 kilograms (kg) U total at this enrichment. The average enrichment of the uranium contained in the waste material processed through the incinerator averaged about 3.25 wt.% U-235. The licensee determined that the mass limit of the incinerator had been exceeded by a factor of 1.6 (approximately 1650 i

grams U-235 - 50.57 kg U total) based on the enrichment (about 3.25 wt.%

U-235) of the uranium contained in the ash and slag. The licensee reported this finding to the NRC on April 28,- 1993.

Since the i

incinerator _was in a shutdown condition when the over-batching problem was identified, the licensee's immediate actions were to maintain the l

shutdown condition until the matter was investigated, adequate corrective actions developed to prevent recurrence, and revised criticality safety controls were approved by the NRC before the system i

l was restarted.

Safety Condition No. S-1 of License No. SNM-1227 authorizes the use of f

licensed materials in accordance with the statements, representations,

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and conditions contained in Part I of the licensee's application dated July 1987, and supplements dated November 12, 1987, through April 29, i

1993.

l Item 1. of Section 4.1.4, "Special Nuclear Material Control," Part I of l

the license application, states:

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" Work stations, procedurally controlled only on the basis of ~a I

safe mass of material, are limited to one safe batch, where a safe batch is defined as no more than 0.45 of a mininum critical mass of the material in process."

l The licensee's investigation report was submitted to the Region V office by letter dated July 1,1993. The licensee considered this report as an interim report because it did not include recommendations or long term corrective actions. The report provided a history of incinerator operations, documentation of the investigation, causal factors, and generic implications of the incident. The report was noted to be comprehensive and adequately described the problems that led to the incident.- The following is a brief summary of the licensee's investigation findings:

(1)

There was no specific CSA developed for the incinerator which was being operated as a batch work station under a generic CSA common to hoods within the facility.

(2)

The uranium measurement systems for the waste fed to the incinerator were inadequate due to non-homogeneity (uranium concentration, moisture content, and material consistency) of the material being measured which effected the accuracy _of the'non L

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j 11 destructive assay system. A time consuming laboratory analytical procedure for the chemical analysis of the ash which had a low priority was not effective for providing timely ' assay data.

Additionally, a lack of adequate procedures and training on l

i effective inventory verification and ash clean-out contributed to poor mass control.

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Corrective actions taken for previously identified incinerator i

mass control problems were less than adequate, including oversight

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and verification that adequate controls were in place to assure that the mass limit of the incinerator would not be exceeded.

4 Regarding long term corrective action, the licensee is in the process of evaluating the economics of operating the incinerator to determine if the unit will be operated in the future or remain shutdown.

If the incinerator is to be operated in the future, the licensee expects to complete these actions by October 1, 1993. The licensee's long term corrective actions will be reviewed in a future inspection and is considered as an inspector followup item (70-1E57/93-09-02).

Failure to maintain incinerator operations within the specified mass i

control limit was identified as a violation of Safety Condition S-1.

However, since the licensee identified the problem and appropriate i

immediate corrective action were taken to maintain the incinerator in safe condition (shutdown) and a comprehensive investigation was performed to determine the cause, this violation will not be cited l

because the criteria in Section VII.B. of the Enforcement Policy were l

satisfied (NCV 70-1257/93-09-03).

5.0 Inspection Exit Meetino (30703)

The scope and results of the inspection were summarized with the licens.ee representatives denoted in Section I on July 30, 1993, at the conclusion of the onsite inspection.

The licensee was informed of the NCVs described in described in Section 2.0, The licensee was also informed that their long term corrective actions for the incinerator would be reviewed when completed.

Regarding the licensee's investigation of the incinerator event, the licensee was informed that their comprehensive report displayed management's concern to assure events were properly investigated.

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