ML20058P501
| ML20058P501 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 12/03/1993 |
| From: | Burris S, Kasnicki D, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058P486 | List: |
| References | |
| 70-1113-93-10, NUDOCS 9312270162 | |
| Download: ML20058P501 (9) | |
Text
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UNITED STATES
-[o arc %g NUCLEAR REGUL ATORY COMMISSION g
REGloN 11 1
.4E, 101 MARIETTA STREET, N.W.., SUITE 2900 7,
-l ATLANTA, GEORGIA 303234199 t
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s Report No.: 70-1113/93-10 i
Licensee: General Electric Company Wilmington, NC 28401 Docket No.: 70-1113 License No.: SNM-1097 Facility Name: General Electric Company Inspection Conducted: October 25-29 and November 1-5, 1993 Inspectors:
Mml 0 cc B,
12_ /M3 Steve Burris', Senior Resident Inspettor Date Signed MNM' b O ct D[3!93 4
Dennis Kasnicki, Fuel Fadility Inspector Date Signed Approved by:
E IM bfr 12MM3 mo Edward McAlpine, Chief
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Date Signed Radiation Safety Projects Section Nuclear Material Safety and Safeguards Branch Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the area of Nuclear Criticality Safety. The inspection included an evaluation of fuel processing in selected favorable geometry operations (milling, slugging, and granulation operations), and an evaluation of the Nuclear Criticality Safety aspects of modifications which were made to the vaporization and hydrolysis segments of conversion lines. A Management Meeting was held on October 26,~1993, to discuss GE safety program status.
Results:
Within the scope of the inspection, no violations or deviations were identified. Regarding the selected favorable geometry operations, it was concluded that General Electric was exercising adequate control over the containment of fuel. Regarding the conversion line modifications, it was concluded that the modifications were administered in accordance with applicable license and procedural requirements. Two weaknesses regarding the Technical Report associated with these modifications are discussed in Paragraph 3.e.
One issue concerning the maintenance of Technical Reports was identified and will be tracked as an Inspector Followup Item.
(IFI 93-10-01) 4 i
9312270162 931203 PDR ADOCK 07001113 C
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REPORT DETAILS t
1.
Persons Contacted
- S. Babb, Manager, Uranium Recovery
- G. Bowman, Senior Program Manager, Compliance Improvement
- D. Brown, Manager, Support & Environmental Programs
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- M. Chilton, Manager, Fuel Chemical Manufacturing
- R. Foleck, Senior Specialist, Licensing Engineering
- T. Hauser, Manager, Environmental, Health and Safety and Nuclear Quality Assurance
- J. Huffer, Criticality Safety Engineer l
- B. Kaiser, Manager, Fuel Fabrication Manufacturing
- R. Keenan, Senior Program Manager, Compliance Auditing
- R. Lewis, Senior Radiation Safety Engineer
- D. McCaughey, Engineer, Re-Engineering Team
- S. Murray, Manager, Radiation Safety Engineering 4
- S. Selby, Acting Manager, Powder Production
- S. Smith, Radiation Safety Monitor
- J. Taylor, Principal Engineer, Criticality Safety Engineering
- R. Torres, Manager, Radiation Protection
- C. Vaughan, Manager, Regulatory Compliance
- F. Welfare, Acting Manager, Criticality Safety Engineering
- P. Winslow, Manager, Licensing and Nuclear Material Management I
Other licensee employees contacted during this inspection included engineers, technicians, operators, security personnel, and office personnel.
- Attended exit interview on November 5, 1993
- Attended exit interview on October 29,'1993 9
2.
Evaluation of Fuel Containment in Favorable Geometry Mill,- Slug, and Granulation Operations (88015)
During daily tours of the General Electric (GE) facility, various operations were observed to ensure adherence to posted safety limits, verification of established separation distances, storage. locations and tamper-proofing activities, and the control of special nuclear material (SNM) during all phases of observed activities.
In addition to these inspection objectives, the inspector reviewed the licensee's nuclear criticality control devices and measures in effect during this 1
inspection period to assure that the licensee's program provided a high degree of reliability for the prevention of an inadvertent criticality.
The inspection also included reviews of the licensee's site procedures, design basis and evaluations and activities associated with the operation of the systems. The inspector reviewed the posted safety 1
limits to verify that the operations staff were in compliance with regulatory requirements during all site tours. The following procedures, documents, drawings and supporting evaluations were reviewed:
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2 Safety Analysis Criticality Safety Analysis for the Hammermill, dated Ndvember 27, 1975 (approved material enrichments up to 3.35 percent)
Criticality Safety Analysis for the Hammermill dated February 25, 1977 (approved material enrichments up to 4.0 percent)-
Criticality Safety Analysis for the Hamermill dated February 22 and 26, 1992 (approved material enrichments up to 5.0 percent)
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Field Change Request 707 for the MSG Line dated July 14, 1975-Criticality Safety Analysis for FCR 707 and 1368 GEKEN0 Computer Run Sheets for FCR 707 and 1368 Drawings l
t No. 6 Hammermill Installation, 0398E75 sheets 1, 2 and 3 No. 6 Hammermill Piping Installation, 0390E75 sheets 1 and 2 Line No. 6 Mill, Slug and Granulate Installation, 6291E75 Line No. 6 MSG Startup Check List and Punch List Granulator Hopper Drawing 288-73DK Hopper Drawing 0381D75 Hopper for Hammermill Drawing 13C7021 Modified Discharge Funnel for Oscillating Granulator 113D3319 Procedures Process Requirements and Operating Documents (PROD) 10.45, l
Rev. 25, Operating Instructions for Hammermill 1-6 and 10 and Nuclear Safety Release / Requirements (NSR/R)
PROD-10.50, Rev. 21, Slug and Granulate (Nos.1-6 and 10 Mill Only Dump Station) and NSR/R PROD-90.64, Rev. 1, hie Sluggers Lines 11 and 12 and NSR/R Nuclear Safety Release / Requirements No. 01.12.12, for the Slugger, Granulator and Utility Hood i
The inspector verified that the Nuclear Criticality Safety Limits for each of the observed activities were being-implemented. This was accomplished by direct observation of the licensee as discussed below.
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6 Criticality safety limits were being maintained as follows:'
1 use of approved containers only all material added to the process was within the allowed material-percentage -specifications l
each container added was within the gross material weight -
specifications each can added was verified as dry powder
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,1 hoods were observed to contain no more~than the authorized number I
L of containers 1
during' processing filled cans were not_ being elevated on the lift j
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inspection and cleaning of the hood areas was'being performed as j
required by the appropriate NSR/R q
l automatic operation of the systems were verified.per the NSR/R; I
vacuum cleaners were stored in approved locations g
operationspersonnelusedtheappropriaterespiratorduringhoodl cleanout j
no unauthorized activities were performed inside the_ hooded _
portion of the slugger during operation of the press all conveying hose connections were double clamped to assure a
geometry configuration-q 1
material accountability scales were being calibrated at-the-required frequencies i
all access doors were being maintained as closed during mill operation-j
.1 interlocks, safety switches and operating switches 'were operable -
and had not been defeated The inspector discussed NCS requirements _with operations personnel-on-several different shifts to determine.the operators knowledge of 4
i criticality safety and the reasons for these. requirements. -Each operator interviewed appeared-to be. knowledgeable of the NCS' requirements and the basis'for these requirements.
In' addition to these
_ discussions on NCS, the inspector verified.that operation personnel were 1mplementing the following requirements:
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operations personnel were knowledgeable of process procedures and these procedures were available for reference l
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4 operations personnel were maintaining the necessary documentation I
and logs as. required for.each specific work station 1
. operations personnel were alert and attentive to their particular work station during each observed shift -
l all personnel interviewed were responsive and cooperative with' the :
inspector
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The inspector reviewed the Criticality Safety' Analysis.for each of the-l referenced Low Enriched and High Enriched work areas. The inspector j
reviewed the referenced evaluations and verified that these documents -
.3 were complete and accurate. The inspector verified that the analysis:
were based on sound safety engineering assumptions and encompassed the.
minimum safety parameters. The analysis-specifled -the _ basis for the analytical calculations and the analysis specified the safety demonstration areas. The analysis appeared to be conservative and g
extrapolated data was based on sound safety assessments.. Each c
extrapolation analysis was rounded down to add conversatism to the I
calculations for each of the enrichment' upgrades.
Criticality safetyi controls were properly identified and listed using the worst credible centents scenario. Each model was created with the pre-established; criteria and.then calculated using GE KENO.4 Computer Code. Based on the results of the~ computational evaluation the licensee found that -
l maximum k-effective + 3 sigma values were all less than the limit of L.97 -
l' k-effective. These values were acceptable for U235 material enrichments; up to 5.0 percent.
Based on these inspections, the inspector concluded that'the~ licensee was maintaining proper control of SNM.
L No violations or deviations were identified in the areas inspected.
3.
Evaluation of the Nuclear Criticality Safety (NCS) Aspects of Modifications to Conversion lines 1, 2, and 4-(88015) a.
The inspector discussed the motivation for making the subject changes to these' conversion lines with GE representatives. GE representatives statedithat the modifications were motivated by a combination of factors.- They had previously made modifications to another conversion line to allow the processing of uranium _ of a l
higher enrichment. These changes included the. automation of-i' process controls, and controls related to NCS. This had contributed' to non-uniformity of controls among the~ different conversion lines and they desired to reestablish uniformity... They had also performed a HAZ0P analysis of; these systems' and that study had indicated some of the modifications. The modifications to the subject conversion lines consisted of the automation of' process' controls, and controls related to NCS.
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b.
Section 2.7.2 of_the license application states that changes which L
do not involve a change in license conditions but which require procedures, facilities or equipment substantially different from those previously used are initiated only after certain conditions are met: Changes which involve a change in the parameters on which criticality safety was established are analyzed and= approved in writing by the criticality safety function and documented by a written criticality safety analysis.
Section 2.7.3 of the license application states that a request for nuclear safety (criticality and radiation safety) analysis is prepared in writing by, or at the direction of, an Area Manager for any proposed new activity or change in activity which may require a proposed change in criticality safety or radiological safety controls. The changed activity will not be initiated until the nuclear safety analysis demonstrating safety of the activity has been completed, a preoperational inspection has been conducted to verify that the installation is in accordance with the nuclear safety analysis, and appropriate procedures and/or instructions are in place. The results of these analyses are documented in nuclear safety reviews and maintained for the period of time they remain applicable and in accordance with the records retention requirements of this license.
Section 2.5.3.1 of the license application states that criticality
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analyses and approval of proposed changes require an independent review by a senior member of the NCS function prior to being implemented Section 4.2.11 of the license application delineates requirements related to Engineered Controls.
The above license conditions were implemented by the following GE safety procedures which were reviewed by the inspector:
P,'P 40-04, " Nuclear Safety Design Criteria", Rev. 9, dated January 8, 1993; P/P 40-05, " Nuclear Safety Review System", Rev. 7, dated January 4, 1993.
c.
GE procedure P/P 40-05, referenced above, defines and establishes the Facility Change Request (FCR) system.
The inspector reviewed the entire FCR documentation package for the subject modifications against the above requirements and discussed various aspects of this documentation with GE representatives. The FCR package contained the following documentation as well as several drawings:
Report No. HEIM-2-G92, "ADU Lines 1, 2, 3, and 4; Vaporization & Hydrolysis; Technical Report", Rev. G, dated September 7, 1993.
Report No. ADU-AEC-1, "TDU Lines 1, 2, 3, and 4; Vaporization and Hydrs'sysis; Active Engineering Controls (AECs)", Rev. 3, dated September 9, 1993.
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Facility Change Request Form No'. 0446.
Temporary Operating Instruction (TOI).No. A-2748, "ADU:
l Upgrade - Start-up' Lines l',-2,.and.4",l dated August 15 1993.
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Pre-Op Functional Test Instructions (FTI) for: lines 1, 2, and.4; dated July 17, 1993, August 13,-1993,-and j
September 4, 1993, respectively.
All of this documentation appeared to meet the requirements of the above referenced license conditions and implementing procedures.-
i, No violations or deviations were identified in the areas U
inspected.
1 d.
The inspector " walked down" the modifications to the vaporization and hydrolysis plant systems, as well as-the corresponding control room, with a GE representative. All'of the modifications appeared to be functioning as intended and no discrepancies were observed.
e.
In reviewing the Technical. Report. listed above (Report No. HEIM !
G92, Rev. G), the inspector noted that the' report's purpose appeared tn be that of a safety technical report, as opposed to a-broader scope operations or engineering document..As such, it-appeared to be the " master" safety analysis document which would-y either contain or.'make reference to all-other applicable safety analysis documentation.-
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Under the heading " Criticality Safety", the; report ' discussed'the -
various segments of the vaporization and hydrolysis systems,-and;
. identified the corresponding NCS-controls. associated with those -
segments, either Active Engineering Controls (AECs).or Passive Engineering Controls or both'. The inspector observed a weakness with this aspect of the report in that the NCS c.ontrols were not discussed within the context of the NCS. accident scenarios which identified their necessity. A GE. representative stated that, in i
general, the considered accident scenarios are sometimes, but not always, documented in the Criticality Safety Analysis. This'GE representative also stated that sometimes controls are placed on two. independent parameters, e.g. mass.and geometry, in lieu-of considering accident. scenarios. The ' inclusion of accident scenarios would, as'a minimum, illustrate the NCS upsets which the controls are intended to preclude. In some instances the perceived upsets may be obvious but in other instances they may not be;.
further, " obvious" is a subjective term.
Explicitly delin_ eating the NCS accident scenarios.and relating them to'the NCS~ controls identified would. document the perceived NCS upsets, and would serve as a resource for making that kind of knowledge readily available for present and future use, e.g. for training andlfor future FCR evaluation. The lack of this kind of documentation-results in re-thinking the purpose of the ' controls every time-they
7 are considered. Having' neglected to do this appeared to be a deficiency in the implementation of GE's management objective, "00ALITY AND REGULATORY AT THE SOURCE; educate operators to the
" WHYS" of safety", which was presented at the Management Meeting on October 26, 1993.
As stated above, this Technical Report appeared to be the " master" safety analysis document for the establishment of NCS controls (and Radiation Safety controls). The inspector observed another weaknets related to this Technical Report in particular, and to all sucn Technical Reports in general. GE did not have any administrative mechanism in place for keeping the Technical Report up to d&te with subsequent changes to the plant systems or changes to related documentation. The inspector observed evidence of erosion of the integrity of the. Technical Report, although 'perhaps minimal, already. The Technical Report referenced another document listed above: Report No. ADU-AEC-1, "... Active Engineering Controls (AECs)", Rev. 0; but the most recent version of this document in the FCR documentation package was Rev. 3.
(Report No. ADU-AEC-1 is a tabular listing of system related AECs and their characteristics.) Also, at least one subsequent FCR had been processed, or was being processed, for this system and did not appear to be causing a corresponding reevaluation of the Technical Report. A discussion with a GE representative indicated that GE has been, and is still working on developing such an administrative mechanism, but has not yet compieted it's development or implementation. NRC is highly interested in GE's ability te maintain the integrity if their established safety basis for plant systems. Accordingly, the completion of GE's i
intended actions on this administrative mechanism will be followed up on as Inspector Followup Item 93-10-01.
4.
Management Meeting (88005, 94702)
On October 26, 1993, a management meeting was held at the site to discuss the status of the licensee's safety pronrams.
An attendance list and the handouts are included as Attachment 1 to this report.
During the meeting, licensee representatives discussed the current status of and future directions for safety programs at the site.
5.
Exit Interview The inspection scope and findings were summarized on October 29 and November 5, 1993, with those persons indicated in Paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection results. Although reviewed during this inspection, i
proprietary information is not contained in this report. Dissenting comments were not received from the licensee.
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ATTACHMENT 1 MANAGEMENT MEETING ATTENDEES Ceneral Electric Nuclear Enerav C. Kipp, General Manager, GE Nuclear Energy Production W. Ogden, Acting Manager, Nuclear Fuel & Components. Manufacturing T. Hauser, Manager, Environmental, Health & Safety and Nuclear Quality Assurance C. Vaughan, Manager, Regulatory Compliance M. Chilton, Manager, Fuel Chemical Manufacturing P. Winslow, Manager, Licensing and Nuclear Materials Management F. Jackson, Manager, Human Resources and Community Relations U. S. Nuclear Reaulatory Commission - Region II Stewart Ebneter, Regional Administrator Douglas Collins, Chief, Nuclear Materials Safety and Safeguards Branch U. S. Nuclear Reaulatory Commission - Office of Nuclear Materials Safety and Safeauards Edwin Flack, Licensing Project Manager
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