ML20058P674
| ML20058P674 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 12/08/1993 |
| From: | Mcalpine E, Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058P669 | List: |
| References | |
| 70-1113-93-11, IEB-93-001, IEB-93-1, IEIN-93-077, IEIN-93-77, NUDOCS 9312270227 | |
| Download: ML20058P674 (8) | |
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Report No.:- 70-1113/93-11 j
Licensee: General: Electric Company Wilmington, NC-28402 4
i Docket No.: 70-1113.
License No.: SNM-1097:
Facility Name: General Electric Company l
i Inspection Conducted: November 15-19, 1993 Inspector:
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12 /8 !9 3 G. L. Troup, Fuel Facility Rroject Inspector Date Signed-
-Accompanying Personnel:
E. J. McAlpine, Chief, Radiation-Safety I
Projects Section (November 17-19,.1993)
' Approved by:
NfMl MS 12/8[93 w
E. J. McAlpine,- thief l-Date Signed Radiation Safety Projects Section Nuclear, Materials; Safety and Safeguards Branch.
Division of Radiation Safety and Safeguards y
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SUMMARY
s Scope:
<4 This routine,. unannounced' inspection was conducted in the areas of managementJ l
controls, organization, nuclear criticality safety, facility changes,
. maintenance, operations and NRC bulletins and notices.
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Results:-
q In the areas inspected, a non-cited violation was identified for the failure
. to comply with procedural requirements for the~ completion of facility. change requests. Several changes in the organization have been. implemented to place -
greater emphasis on moving the responsibility for safety and quality to the
.i source. Operations were being conducted in accordance with the requirements)
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of the' license'.
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9312270227 931208 PDR ADOCK 07001113 C
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- S. Babb, Team Leader, Uranium Recovery Proc.ess -
- D. Brown, Team Leader, Environmental Processes
- M. Chilton, Manager, Chemical Product Line
- R. Foleck, Sr. Specialist, Licensing Engineering T. Hauser, Manager, Environmental, Health and Safety & Nuclear Quality Assurance
- J. Huffer, Engineer, Criticality Safety Engineering
- B. Kaiser, Manager, Fuel Fabrication Product Line
- R. Keenan, Program Manager, Compliance Auditing C. Kipp, Manager, GE Nuclear Energy Production
- D. McCaughey, Engineer, Regulatory Team - Fuel Manufacturing Operation S. Murray, Manager, Radiation Safety
- E. Palmer, Team Leader, Fuel Manufacturing Operation Maintenance Support
- G. Smith, Team Leader, Operations Support
- J. Taylor, Principal Engineer, Criticality Safety Engineering
- C. Vaughan, Manager, Regulatory and Environnental, Health & Safety
- F. Welfare, Manager, Criticality Safety Engineering
- P. Winslow, Manager, Emergency Preparedness, Security, Material Control and Accountability Contractor Employees C. Williams, Payroll, Inc.
The inspector also interviewed area coordinators, operators, engineers and administrative personnel during the inspection.
- Denotes those attending the Exit Interview on November 19, 1993.
2.
Organization Changes (88005) a.
In Inspection Report (IR) 70-1113/93-06, it was noted that the former Manager, Nuclear Fuel and Components Manufacturing had been promoted and that a permanent replacement had not been designated at that time. The new manager has been designated and is in pl ace. However, he has the title of General Manager, GE Nuclear Energy Production, which will require that a license amendment be submitted to change the position title.
b.
The Acting Manager, Criticality Safety Engineering has been made permanent. Several personnel moves which resulted from an organization change announced on November 1,1993 resulted in the consolidation of functions and new titles being assigned. These changes still comply with the license organization and functional 4
descriptions, and maintain independence of the safety' functions.
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The organization change announced on November I changed the j
structure in the production' organization, resulting in thez establishment of ". teams" responsible for different operations.
j The former managers for these operations have been designated
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" team leaders." : An additional-change places La team in the chemtc31 organization which is tasked with improving thel operational interface between the operators and safety: activities..
j This is part of the move to place more responsibility:for-safety and quality at-the source rather than having'the responsibility for these functions in other organizations-separate from the i
organization (s) responsible for performing' the work.
o d.
The inspector noted that the two "long term"' items remaining at-1 the end of the Performance Improvement Program (PIP), operator-training and procedure improvement, were directly related to thef, new concept of quality and safety at the source. Several.
individuals formerly involved in these activities had been j
transferred to other duties'but a " team leader" had been hired to work primarily on procedures. The inspector informed licensee j
management that if the persons on the_ floor will be responsible for the implementation of safety and quality.as part of their:
a other duties, then it is-incumbent on. management to assure that-they have the necessary skills and tools' to perform their new functions.
Licensee management agreed. The on-going activities-of improving the procedure system and the training of personnel will continue to be reviewed during future inspections.
j Within the scope of the inspection, no violations or deviations werei
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identified.
3.
Facility Modifications and Changes (88005, 88015, 88020).
q a.
Part I, Chapter 2, SecNn 2.7.3 of the license application states :
that a request for nuclear safety (criticality and radiation safety) analysis is prepared 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 1
demonstrating safety of the activity has been completed, a-1 preoperational inspection of the has been conducted to verify thatL y
the installation is in accordance with the nuclear safety 1
analysis, and the appropriate procedures and/or instructions are in place.
4 b.
Implementation of these requirements are specified in Practices-l and Procedures (P/P) 40-05, Nuclear Safety Review System, which_
establishes the Facility Change Request (FCR) system.. Additional-.
instructions to the nuclear safety staff are contained in Nuclear.
Safety. Instructions (NSI) E-3.0, Nuclear Safety Review Request, and NSI E-1.0, Nuclear Safety Review Records.
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3 c.
The inspector had previously reviewed FCRs associated with the installation of new equipment and the relocation of existing equipment in the Gadolinia Shop.
FCR 92.684, Install New Rod Loader in the Gad Shop was incomplete during the -last inspection but was shown as " closed" on the current Facility Change Request Listing (Nov. 17.)
d.
The nuclear criticality safety analysis was completed using accepted methods, and was reviewed and signed by the required second reviewer on September 16, 1993. However, the inspector noted that the FCR form had been signed as " Approved for-Operation" by both the NSE Manager and the Area Manager on August 30, 1993 even though there were three requirements on the FCR form which were not signed as " completed and accepted" in addition to the nuclear criticality safety analysis not being completed. The three requirements were " operating procedure,"
" training (maint/oper)" and " updated drawings." P/P 40-05 requires that the requestor must provide a new or revised operating procedure for review by NSE prior to approval-to operate, provide training to maintenance and operators and document the content and attendees of the training to NSE prior to completion, and provide final (as-built) drawings prior to completion.
FCR 92.684 appeared to have been improperly released for operation, in violation of the P/P and the license application requirements.
e.
The cognizant manager discussed this situation with the inspector.
The completion of the installation of the new loader was identified at the end of August as an urgent item. But to test the machinery required that it be " operated." The loader was identical to the loaders which had been installed in the uranium dioxide area and for which an approved nuclear safety analysis existed.
Since the new installation moved other equipment farther away, reducing the interaction, a letter to file, reviewed and
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approved by two qualified analysts, dated August 27, 1993 concluded that, based on the calculations performed up-to that time and the less reactive installation, " interaction safety will be demonstrated."
(This was subsequently shown on September 16.)
On this basis, the system was approved for operation. A Temporary Operating Instruction (TOI) B-2764 had been signed by NSE on August 30, but a copy of the TOI was not in the FCR package or in the NSE file.
(The TOI was subsequently incorporated into PROD 70.56, rev. 5 on October 29, 1993.) The equipment lay-out drawing had been updated on September 3, 1993 but a copy was not sent to NSE.
No specific records of training could be found, but a licensee representative explained that the project engineer had to grant access to operate the equipment through a badge reader-controller (any one putting their badge with a magnetic stripe through the i
reader could not operate the equipment unless the project engineer had programmed the reader to accept that particular badge.) The
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controller produced a list of those persons.who were authorized access at different levels but did not provide the date that access was granted.
From discussions with other engineers and managers, the inspector concluded that training had been provided but the documentation was lacking.
f.
The failure to provide the content of the training and the attendees, and closure of the FCR package without the.three requirements being signed off is a violation of Section 2.7.3 of the license application. Compliance with Part 1 of the license application is required by Condition S-1 of License SNM-1097.
In this and previous inspections, FCR packages reviewed have been completed properly. The inspector determined that this particular situation was an isolated case and was a paper problem rather than representing a significant safety issue. When this issue was brought to management personnel's attention, actions were taken to bring the necessary materials into the package. Management representatives acknowledged that the completion of the package had been deficient and committed to conducting a review of the FCR procedure to better define what is intent of the requirements, what constitutes " completion" and how completion of these requirements would best be documented.
This NRC-identified violation is not being cited because criteria specified in Section VII.B of the NRC Enforcement Policy were satisfied. Completion of these actions will be reviewed during subsequent inspections.
The following non-cited violation was identified and reviewed during this inspection: NCY 93-11-01, Failure to Document Completion of Requirements of a Facility Change.
4.
Audits (88005, 88015) i a.
Part I, Chapter 2, Section 2.8.3 of the license application requires that an audit be conducted of the nuclear criticality safety program every two years. The audit is to be conducted by an " appropriate function" outside of the GE-Wilmington organization. This audit was due to be conducted in 1993.
b.
The audit was conducted during the period October 18-22, 1993 by a group of consultants formerly employed at the Oak Ridge National Laboratory. The audit report was received by the licensee during the inspection period on November 17. The inspector reviewed the audit report and the findings, and discussed the findings with licensee representatives. Based on these discussions, the inspector determine that the principal findings related more to documentation issues and did not represent any issues of immediate safety significance. The licensee had not had sufficient time to adequately review the findings and take corrective actions. The resulting corrective actions will be reviewed during subsequent l
inspections.
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5 c.
One audit finding dealt with an operations situation which occurred during the audit period. The conditions were' reviewed with management representatives during the inspection. _Several-
-l changes-to process systems and the control system were ' identified and were in the process of being approved and implemented._ These
.l will be reviewed in conjunction with the audit findings and plant -
operations.
d.
The licensee is also required to-have an outside audit of the radiation protection program conducted every two years, which is.
also due in 1993. As significant changes to the program will result from the implementation of the new requirements of 10 CFR 20, which become effective on January 1, 1994. -Licensee representatives informed the inspector.that-their intention was-to 3
delay the audit until after the new requirements are implemented.
A letter will be~ sent to the Office of Nuclear Materials Safety j
and Safeguards stating that the audit-would be delayed and the t
reasons for the delay.
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Within the scope of the inspection, no violations or deviations were identified.
5.
Maintenance (88005, 88025) i The maintenance group (FM0 Maintenance Support Team) is under_the
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Manager, Fuel Fabrication Product Line. -The inspector discussed.the organization and conduct of the group with the team leader. 'While the 1
team is under the fuel fabrication manager,.they have responsibility for performing maintenance in areas-under the cognizance of the' chemical-product line managers and team leaders as well. ' Separate organizations-perform maintenance in the Fuel Components and Service Components' facilities.
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Maintenance coverage is provided by personnel who work the same shift sequence as the operations personnel, while specialized functions are-normally handled on the day shift with ' call-in work is' available for the'-
i backshifts. Maintenance personnel perform preventive' maintenance as-0 well as emergency repairs and also perform inspections and calibrations.
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The inspector discussed other areas, such as staff size, qualifications, turnover of staff, as well.
l Within the scope of the inspection, no violations or deviations were-identified.
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Information Notices and Bulletins (88005, 88015) a.
Information Notice (IN) 93-77, " Human Errors That Result'in Inadvertent Transfers of Special Nuclear Material-at Fuel Cycle.
i Facilities" was issued on October 4, 1993. The inspector verified
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that the IN had been received by the licensee and had been distributed to cognizant managers for their information and appropriate action.
The inspector reviewed the response of an Area Manager concerning this IN, which indicated that a very detailed review of the process had been conducted to look for situations where human errors could affect the handling of uranium. Three potential-areas were identified and corrective actions (and schedules) listed to solve these potential problems.
b.
Supplement I to Bulletin 91-01, " Reporting Loss of Criticality Safety Controls," was issued to clarify the reporting requirements and to require that licensees report to the NRC when the required actions are complete. The licensee responded to the Supplement on October 20, 1993 and stated that the reporting criteria and management implementation procedures meet the reporting criteria.
l P/P 40-32, " Criticality / Radiological Safety Event Communication and Notification" was revised by a mandatory modification on October 14, 1993 to specify reporting requirements equal to Supplement 1.
The inspector noted that this change replaced the reporting requirements which were made in an agreement in June, 1991. The licensee stated that they would officially inform Region II in writing that the agreement had been changed.
7.
Operations (88015, 88020)
During the inspection, various areas of the facility were toured by the inspector to observe the conduct of operations. This included the observation of conduct in the control rooms, response of the operate ;
to alarms and process, and knowledge of the operators of the statu: F various systems. The inspector also reviewed operations logs in the control rooms and then observed the status of the systems on the floon During tours of the operations areas, the inspector observed that housekeeping was generally good,.except for the area under the Line 3-hydrolysis equipment, where there was process liquid accumulating in the dike. The inspector discussed this with licensee representatives who acknowledged that there was a problem with the seals on the transfer pump.
Corrective actions were being planned to reduce or eliminate the I
seal leakage.
The inspector observed that areas around fire fighting equipment were clear, flammable liquids were stored in appropriate containers, and there was no significant accumulation of moderating or combustibla materials.
Storage and accumulations of fissile materials were in accordance with posted requirements.
i Within the scope of the inspection, no violations or deviations were identified.
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Exit Interview (30703)
On November 19, 1993, the scope of the inspection and the findings were discussed with those persons identified'in Paragraph 1.
A detailed discussion of the problem with the-FCR process and the NCV (paragraph 3) was held. No dissenting comments were received from licensee representatives.
I Although proprietary documents were reviewed during the inspection, the proprietary nature of the documents has been deleted in this report.-
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