ML20057C290
| ML20057C290 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 09/15/1993 |
| From: | Mcalpine E, Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057C286 | List: |
| References | |
| 70-1113-93-07, 70-1113-93-7, IEB-91-001, IEB-91-1, IEIN-93-060, IEIN-93-60, NUDOCS 9309280180 | |
| Download: ML20057C290 (15) | |
Text
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t UNITEo STATES
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NUCLEAR REGULATORY COMMISSION 3*
REGloN 81 2
7, 101 MARIETTA STREET, N.W., SUITE 2900 a
l ATLANTA, GEORGIA 303234199
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Report No.:
70-1113/93-07 Licensee: General Electric Company Wilmington, NC 2840)
Docket No.:
70-1113 License No.: SNM-1097 Facility Name: General Electric Company Inspection Conducted:
uu 6 - September 3, 1993 Inspector: /
<b 7!/J!73 G. L. Troup, Tueltfacility Project Inspector Date Signed j
i Accompanying Personnel:
B. Mallett, Deputy Director, Division of Radiation Safety and Safeguards, RII (September 2 and 3, 1993) l
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[M b1f 9 5[i3 Approved by:
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E. J. McAlpine, Chief
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Date Signed t
Radiation Safety Projects Section Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards s
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the areas of nuclear
'i criticality safety, operations, fire protection, facility changes, NRC bulletins and notices, and programs for the identification of safety issues and concerns. Additionally, the inspection included a review of the preparations for adverse weather (hurricane) although that was not part of the original inspection plan.
Results.
Within the scope of the inspection, no violations or deviations were identified. One identified condition concerning the integrity of coupling guards for rotating machinery which is within OSHA's purview was brought to licensee management attention. The licensee took prompt action to correct the hazard (Paragraph 4c).
The licensee's preparations for the possibility of Hurricane EMILY were timely, thorough and well coordinated.
Process systems were configured such that they could be quickly shut down, if required, or started up in an orderly manner once the situation improved.
Potential hazards from foreign materials 9309280180 930915 PDR ADDCK 07001113 C
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i in outside areas were reduced through removal, clean up or tie down. Timely communication of the situation to workers was also positive (Paragraph 2).
I The licensee has a number of programs in place for handling concerns or safety problems which may be identified by workers but who do not choose to use the normal line supervisory chain to bring these concerns to management's i
attention.
In addition, a new corporation-wide program has been instituted for the identification of concerns or problems (Paragraph 6).
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REPORT DETAILS 1.
Persons Contacted i
Licensee Employees
- S. Babb, Manager, Uranium Recovery J. Bradberry, Sr. Program Manager, Emergency Preparedness and Security
- T. Hauser, Manager, Environmental Health & Safety & Nuclear Quality _
Assurance
- J. Huffer, Engineer, Criticality Safety Engineering
- F. Jackson, Manager, Human Resources & Community Relations
- R. Keenan, Program Manager, Compliance Auditing
- A. Lehmann, Principal Engineer, Fuel Chemical Manufacturing W. Ogden, Acting Manager, Nuclear Fuel & Components Manufacturing
- R. Pace, Sr. Program Manager, Fuel Programs T. Reason, Sr. Engineer, Process Safety
- S. Selby, Acting Manager, Powder Production H. Shaver, Engineer, Radiation Safety Engineering L. Sheely, Sr. Program Manager, Procedures and Training J. Taylor, Principal Engineer, Criticality Safety Engineering
- C. Vaughan, Manager, Regulatory Compliance
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- F. Welfare, Acting Manager, Criticality Safety Engineering
- P. Winslow, Manager, Licensing & Nuclear Material Management Contractor Employees C. Williams, Payroll, Inc.
The inspector also interviewed area coordinators, operators, engineers, safety specialists and administrative personnel during the inspection.
- Denotes those attending the Exit Interview on September 3, 1993.
2.
Hurricane-Related Activities (88005, 88020) a.
Hurricane EMILY was tracking along the coast and it was uncertain where or when it might make landfall. On August 30, the National Hurricane Center issued a Hurricane Watch for coastal areas of North Carolina which included the plant area.
Prior to the issuance of the Hurricane Watch being issued, the licensee had begun preparations for severe weather in anticipation of the hurricane approaching the area. On August 30, a special notice was issued to all employees of both NF&CM and the Aircraft Engines facility regarding work schedules and special announcements for changing conditions.
Preparations included removing materials from outside areas, clearing construction materials from roofs and outside areas and preparing process systems for an orderly shutdown.
Planning meetings were held with all of the site facilities participating in the planning activities, i
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2 b.
After the Hurricane Watch was issued, steps were initiated to process materials in the Powder Production area and bring the systems to a condition of " Hot Standby" (as materials were processed, that part of the system was shutdown and material flow stopped but heated equipment, such as vaporizers, were maintained at temperature). The systems in Uranium Recovery were also shutdown as material was processed, except for those systems which were required to process continuous waste streams. Outside waste tanks were lowered in volume and the waste lagoons were equalized to provide additional capacity in the event of heavy rains.
c.
At 11:00 a.m. on August 31, the Hurricane Watch was lifted for the Wilmington area as the hurricane tracked to the north. A final meeting was held that afternoon to coordinate activities and release the plant to resume normal operations.
Those process systems which were in " Hot Standby" were restarted in an orderly sequence.
Normal operations were in place by September 1.
d.
During this period, the inspector observed the various activities being conducted to prepare for the hurricane, and also participated in the planning meetings. He observed the activities and operations to bring the systems to shutdown and outside activities to minimize the potential hazards from flying debris and materials.
Following the ending of the watch, the inspector observed activities to bring the systems back up to normal operations. Both the shutdown and startup were conducted in an orderly manner in accordance with the operating procedures.
Although minor problems were encountered with the startup (which were of the type often encountered during normal start-ups) no significant issues were identified during this period.
No violations or deviations were identified.
3.
Fire Protection (88025, 88055) a.
The inspector reviewed records and completed work orders to verify that periodic tests and inspections of fire protection systems and equipment had been conducted.
Items inspected included:
(1) water flow test (this verified that water flow occurred from various hydrants; flow measurement will be performed by the insurance inspector)
(2) fire water pond inspection (3) fire pump suction strainer cleaning and inspection (4) annual fire pump preventive maintenance b.
The inspector also reviewed records documenting the annual fire hose tests.
However, the fire hoses in the controlled access area had not been tested. New hoses had been installed in 1992 (as confirmed by the tags attached to each hose).
National Fire Protection Association (NFPA) standard 1962, Standard for the Care, Use and Testing of Fire Hose, including Couplings and Nozzles, requires that new hoses be hydrostatically tested at " intervals not exceeding five
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i years, and three years thereafter." The inspector asked how this requirement was satisfied. To resolve this, during the inspection period licensee personnel initiated a change to Wilmington Site Safety,' Health and Fire Protection Manual procedure 505, Inspection and Maintenance of Fire Fighting Equipment, to require an annual visual inspection of hoses in the controlled area and replacement with new hoses every five years.
The inspector had no further questions.
c.
The inspector reviewed the report from the insurance carrier's last loss prevention evaluation, which was conducted in September, 1992.
The report stated that the licensee had " good housekeeping practices, adequate control of potential ignition sources and a well-maintained fire protection system." Observations by the inspector did not identify any conditions which were contrary to these findings.
4.
Modifications and Changes (88015, 88020) a.
During the last shutdown period, the licensee replaced equipment in the Solvent Extraction (SX) cell with new equipment.
The inspector reviewed the Facility Change Request (FCR) package for this replacement and discussed the nuclear criticality safety review with cognizant individuals. As the new equipment was of similar dimensions to that which was removed and the spacing of the i
equipment did not change an interaction analysis was determined not to be required.
Process parameters (such as concentrations) for the new equipment are within those previously evaluated as well.
b.
A Temporary Operating Instruction (TOI) was approved for testing to evaluate the performance of the new equipment.
This TOI included specific objectives for the tests, a test overview, and specific operating instructions for conducting the tests. The inspector reviewed the TOI and determined that the conditions were within approved process limits and the TOI was approved as required.
c.
During a tour of the SX cell on September 2, the inspector observed the new equipment and noted that the pulsers were operating.
However, the coupling guard for the "A" column pulser, while in place, was not secured to the base with the proper bolts. This constituted an industrial safety hazard. When brought to the cognizant manager's attention, an emergency work order was initiated to correct the situation. The manager said that a review would be made of the coupling guards on rotating machinery, in general, and r
that verification of proper installation would be made part of the return to service requirements after maintenance was performed.
d.
An additional change reviewed during the inspection was a major change to the process area where Gadolinia materials are handled and processed (" Gad shop"). When the shop was originally layed out and analyzed, the nuclear criticality safety was established using the Solid Angle Method (an approved method). The current modification i
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installs more equipment with the resulting increase in the amount of fissionable material. A new set of analyses was being performed.
using approved computer methods.
Initial calculations identified that the interaction of equipment in the Gad shop and material stored on the opposite side of a non-structural wall was actually the most reactive condition. Additional calculations were required as the result of this interaction, and were being run during the inspection period, using approved calculational methods. TFe final result will be reviewed during future inspections.
No violations or deviations from NRC requirements were observed.
5.
Bulletins and Notices (88005,88015) a.
Bulletin 91-01, Reporting Loss of Criticality Safety Controls, was issued on October 18, 1991 and requested that licensees inform the NRC of their criteria and procedures to ensure the prompt evaluation and reporting of conditions and events involving criticality. After receiving comments from licensees about the bulletin and the associated reporting requirements, the NRC issued Supplement 1 on July 27, 1993 to clarify reporting requirements and require reporting of actions taken to the NRC. The inspector determined that the supplement had been received by the licensee and routed to the appropriate managers. The Supplement requires a response within 60 days of the bulletin.
Licensee representatives stated that they were working on their response but might ask for an extension in the response date since the supplement is dated July 27 but was not received until August 16.
The licensee is currently making reports concerning conditions or events which involve criticality safety issues under the terms of an agreement with Region II. This agreement will remain in effect until the licensee has made the required submittal and it has been approved.
This will be reviewed during subsequent inspections.
b.
Information Notice 93-60, Reporting Fuel Cyclc and Materials Events to the NRC Operations Center, concerned problems with reports made to the NRC when callers were not prepared to answer the questions about the facility or the event.
Thi.s Notice was receivert by the licensee on August 23 and copies were provided to cognizant managers, who are reviewing how such reports are made and possible changes which might be made to improve the reports. No specific action or response is required for NRC Notices.
6.
Employees Concern Program (88005, 88015, 88020) a.
10 CFR 70.7 prohibits licensees or licensees' contractors from discriminating against enployees for engaging in certain protected activities as defined in Section 210 of the Energy Reorganization Act of 1974.
Included in the protected activities is taking action to initiate NRC proceedings or raise safety issues to the NRC or the licensee. A special inspection procedure was issued for the review
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5 of licensee programs which might be in place to permit employees to raise safety issues or other concerns without fear of retribution, y
A questionnaire for this inspection was provided with the procedure.
b.
Through discussions with management representatives and the review i
of applicable plant procedures, the inspector completed the questionnaire, which is included as Appendix A of this report.
In addition to completing the questionnaire, the inspector discussed
-how one could raise a safety concern or issue with workers at various levels. All were aware that there were mechanisms to raise issues and that it could be done anonymously, if desired.
7.
Report Follow-up (88015, 88020) 6.
On August 22, 1993, the licensee made a notification to the NRC j
Operations Center of the possible loss of a criticality control.
Later that same day, the licensee made a notification that, upon further investigation, the control had not been lost and the notification was being " withdrawn."
b.
The licensee was processing uranium hexafluoride from a cylinder in a vaporizer to a hydrolysis column when a blockage developed in the line. To permit maintenance to work on the blockage, the control system was placed in " unanticipated shutdown" and the heaters turned off. After the blockage was cleared and the piping reassembled, it was necessary to perform a pressure test using nitrogen on the system. When the line was pressurized, the operator received a
" ready" signal on the control panel and-took this to mean that the system was ready to resume flow from the vaporizer.
Knowing that the only pressure on the system was from the nitrogen and the heaters were off, he thought that a control to prevent backflow from hydrolysis had been lost, and commenced system shutdown and notifications of a loss of control.
c.
Subsequent review of the controls and Boolean logic for the system showed that the " ready" signal was to permit opening a flow control valve, not to resume system operation.
Had normal operations been attempted the functional sequence scan would have detected that the heaters were off and did not satisfy the logic.
The operator's actions were acknowledged as correct in this circumstance because he 1
felt that the control was lost.
d.
The review of this situation identified several actions which would improve operations and the operator's understanding of the signals.
These changes were identified and scheduled to be incorporated into the control logic and program for all lines when modifications were completed on the last line.
The operating procedure was also being modified to clearly state that the " ready" light means that the flow control valve could be opened.
c No violations or deviations were identified.
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Management Change (88005)
On July 2,1993, it was announced that the Manager, Nuclear Fuel and Components Manufacturing was being promoted and that a new manager would be appointed (Report 70-1113/93-06, paragraph 2.a).
On August-17, 1993, a new manager was appointed by the Vice President, GE Nuclear Energy.
When this individual arrives on site, an. indoctrination program will be conducted to meet the requirements of Section 2.5.1 of the license application, 9.
Exit Interview (30703) 1 The inspection scope and results were summarized on September 3,1993 -
l with those persons indicated in Paragraph 1.
The inspector described those areas inspected and discussed in detail the results and the inspector's observations.
No dissenting comments or opinions were received from licensee representatives.
Although proprietary documents and processes were reviewed during the inspection, proprietary information is not contained in the report.
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Report 70-1113/93-07 i
Appendix A i
Employee Concerns Program-t i
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PLANT NAME: WILMINGTON LICENSEE: GENERAL ELECTRIC DOCKET NO.: 70-1113 EMPLOYEE CONCERNS PROGRAMS A.
PROGRAM:
1.
Does the licensee have an employee concerns program?
Yes There is not one single program but several which deal with different issues and are related.
(Essentially six programs)
Personnel Appeals - Peer Review Compliance Hot Line - Safety Issues 10 CFR 21 - Quality Concerns Integrity Program - Corporate and Business Unit Nuclear Criticality Controls (Bulletin 91-01)
Fire Extinguisher Hot Line (a lower level program but still an important safety concern program) as well as the 10 CFR 19.12 requirements The Integrity Program is a new corporate program focused on financial issues (such as ethical business practices, supplier relationships, compliance with Antitrust Lat!s, insider stock trading) but is also available for health, safety and environmental issues.
2.
Has NRC inspected the program? Report #70-1113/93-07 Programs were previously inspected and documented in reports 70-1113/88-05 and 70-1113/91-06.
B.
$60PE:
1.
Is it for: One or more programs apply.
a.
Technical?
Yes b.
Administrative?
Yes c.
Personnel issues?
Yes 2.
Does it covar safety as well as non-safety issues?
Yes 3.
Is it designed for:
a.
Nuclear safety?
Yes b.
Personal safety?
Yes Industrial safety and radiological safety.
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PLANT NAME: WILMINGTON LICENSEE: GENERAL ELECTRIC DOCKET NO.: 70-1113 i
c.
Personnel issues - including union grievances?
Yes 4.
Does the program apply to all licensee employees?
Yes 5.
Contractors?
Yes l
Safety, quality and integrity issues.
Contractors handle personnel issues within their organization and procedures.
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Does the licensee requirc its contractors and their subs to have a similar program?
Yes Purchase orders for contractors require that they have similar i
programs a_nd comply with licensee's programs for safety and quality.
7.
Does the licensee conduct an exit interview upon terminating employees asking if they have any safety concerns?
Yes i
After a written allegation which was also sent to the NRC in 1992, greater emphasis has been placed on conducting out-going interviews and looking for safety concerns.
C.
INDEPENDENCE:
1.
What is the title of the person in charge?
Various individuals had primary responsibility for the programs.
Appeals
- Manager, Human Resources Compliance - Manager, Quality Assurance 10 CFR 21
- Manager, Quality Assurance or Manager, Regulatory Compliance Integrity - Corporate Ombundsperson or business unit 0mbundsperson 2.
Who do they report to?
Manager, Human Resources reports to the Manager, Human Resources, GE Nuclear Energy with a dotted line to Manager, Nuclear Fuel and Compor 2nts Manufacturing (NF&CM)
Manager, Quality Assurance reports to Manager, NF&CM Manager, Regulatory Compliance reports to the Manager, Environmental Health and Safety and Nuclear Quality Assurance with a dotted line to the Manager, NF&CM.
The Compliance Ombundsperson reports to the Senior Vice President-Finance.
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PLANT NAME: WILMINGTON LICENSEE: GENERAL ELECTRIC DOCKET NO.:
70-1113 3.
Are they independent of line management?
All are independent of product managers but concerns may be referred to product manager for correction.
4.
Does the ECP use third party consultants?
Generally not on concerns or personnel appeals but have used technical consultants in special circumstances.
5.
How is a concern about a manager or vice president followed up?
This depends on the level of manager, but a concern about a senior manager or a vice president would be referrcd to the Corporate Audit Group for follow up. A special inspection team would probably be appointed to investigate.
D.
RESOURCES:
I 1.
What is the size of the ;taff devoted to this program?
Eight for local programs; not including corporate or business units.
2.
What are ECP staff qualifications (technical training, intervier;ing training, investigator training, other)?
Some are technical, some administrative. All have received or are scheduled to receive Tap Root training.
ECP staff routes incoming concern to designated manager or technical contact.
E.
REFERRALS:
1.
Who has followup on concerns (ECP staff, line management, other)?
Line management or manager of responsible function (QA, safety, etc.).
F.
CONFIDENTIALITY:
1.
Are the reports confidential?
Yes - If the employee so desires.
(Except personnel issues) 2.
Who is the identity of the alleger made known to (senior management, ECP staff, line management, other)?
Need to know basis - requests for confidentiality will be honored.
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PLANT NAME: WILMINGTON LICENSEE: GENERAL ELECTRIC DOCKET NO.: 70-1113 3.
Can employees be:
l a.
Anonymous?
Yes i
b.
Report by phone?
Yes In-plant " Hotline" and "800" lines to Ombundsperson at various i
levels of the corporate structure.
G.
FEEDBACK:
1.
Is feedback given to the alleger upon completion of the followup?
Yes - Different forms depending on program but generally in writing.
" Hotline" responses are generally verbal.
2.
Does program reward good ideas?
Yes Lightning Awards (immediate cash awards) have been given for identification of problems.
3.
Who, or at what level, makes the final decision of resolution?
Dependent on particular programs and severity level of complaint.
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Lowest level possible handles resolution.
4.
Are the resolutions of anonymous concerns disseminated?
No Anonymous concerns are handled and action taken but there is no
" anonymous bulletin board.
5.
Are resolutions of valid concerns publicized (newsletter, bulletin board, all hands meeting, other)?
Not generally but may be recognized through other awards programs.
H.
EFFECTIVENESS:
1.
How does the licensee measure the effectiveness of the program?
Qualitatively - are programs being used and problems identified.
If not used, then program is not effective.
1 2.
Are concerns-a.
Trended?
Yes Especially personnel appeals and compliance concerns (trended by category).
b.
Used?
Yes Trend data used to identify and address problem concerns.
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PLANT NAME: WILMINGTON LICENSEE: GENERAL ELECTRIC DOCKET NO.: 70-1113 3.
In the last three years how many concerns were raised?
Of the concerns raised, how many were closed?
What percentage were substantiated?
i Total Open Substantiated Appeals 38 4
18 (does not include those which were resolved at the first step of the process, which is a verbal discussion with supervisor or first reporting level of management) 10 CFR 21 0
0 0
l Compliance Hot Line 49 0
35 (most were industrial safety issues)
Integrity Mot Line 0
0 0
(new program initiated in July,1993) 4.
How are followup techniques used to measure effectiveness (random survey, interviews, other)?
If possible, before a concern is closed, follow-up with individual to verify action was taken and the individual was notified. This does not necessarily require complete satisfaction but that the-situation was corrected. Obviously, this is not possible with anonymous concerns.
5.
How frequently are internal audits of the ECP conducted and by whom?
Customer audits of Part 21
- two-three years Nuclear Quality Assurance audits Part 21:
three years E&HS audits complaints on variable frequency I.
ADMINISTRATION / TRAINING:
1.
Is ECP prescribed by a procedure?
Yes The plant level programs are spelled out in plant procedures.
Appeals - Employee Relations Manual Procedure PP-51, Peer Review Procedure 10 CFR 21 - Practices i Procedure (P/P) 30-07, Reporting Defects and Noncompliances Compliance Hotline - P/P 30-49, Compliance Hot Line i
Integrity - Corporate directive / booklet 5
PLANT NAME: WILMINGTON LICENSEE: GENERAL ELECTRIC DOCKET NO.: 70-1113 i
Nuclear Criticality Safety Issues - P/P 40-32 and Nuclear Safety Release / Requirement for controlled access area 2.
How are employees, as well as contractors, made aware of this program (training, newsletter, bulletin board, other)?
Initial training covers requirements, especially worker's responsibility to identify safety hazards and potential violations as required by 10 CFR 19.12.
Retraining scripts are being updated to include this as a point to be reemphasized.
i Electronic bulletin boards periodically emphasize use of the compliance Hot Line.
The July,1993 issue of Fuels and Flight (the site newspaper) contained an article emphasizing the individual's responsibility to report problems under 10 CFR 21. The August,1993 issue of Fuels and Flight had articles about both the Integrity program and the Peer i
Review (appeals) process. By use of articles of this type, employees are reminded of their existence and use.
Additionally, related documents (Form NRC-3,10 CFR 21, State OSHA postings) are posted on " official" bulletin boards throughout the plant area.
ADDITIONAL COMMENTS:
The efforts to follow-up and correct identified concerns gives the program visibility among the work force. Discussions with personnel "on the floor" indicated that they were aware of programs, especially the Compliance Hot Line and would use it provided they could not get a problem resolved by discussion with the Area Manager or Supervisor.
Evaluation: There are many levels to try an get a problem resolved.
If it is not ultimately resolved it is probably because the individual did not try.
NAME: G. Troup TITLE: Fuel Facility Inspector PHONE #: (404) 331-5566 DATE COMPLETED: September 3, 1993 6