ML20059A088
| ML20059A088 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 10/15/1993 |
| From: | Bassett C, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059A043 | List: |
| References | |
| 70-1151-93-06, 70-1151-93-6, NUDOCS 9310260217 | |
| Download: ML20059A088 (31) | |
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101 MARIETTA STREET. N.W., SUITE 2900 i, 4 j
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Report No.:- 70-1151/93-06 Licensee: Westinghouse Electric Corporation Commercial-Nuclear Fuel Division Columbia, SC 29250 Docket No.:' 70-1151 (Fuel. Division)
License No.:
SNM-1107 Facility Name: Columbia Nuclear Fuel Plant -
' Inspection Conducted: _' August 16-20 and September 13-16, 1993 Nb QAdCS
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~ Inspector:
.C. H. Bassett, Seni Radiation Specialist Date Signed Approved by:
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93 E.. J. McAlpine, Chief -
Date Signed Q adiation Safety Projects Section Nuclear Materials -Safety and Safeguards Branch '
Division of Radiation Safety and Safeguards
SUMMARY
. Scope:
This reactive, announced inspection involved a review of two events that occurred on July 20 and August 13, 1993.
Both events-had. nuclear criticality safety implications because each involved a spill of uranium dioxide powder
.inside a non-favorable geometry. enclosure. The inspection also involved review of the licensee's Employee' Concern Program.
-Results:
.The events'noted above, involving spills of uranium dioxide powder,- were the result ~of failure to follow procedure. The' events are recorded-in the NRC Incident Response Database as numbers 25812 and 25915.
In'each instance, the
-licensee's procedures governing operations of the involved equipment. required the operators to check the non-favorable geometry enclosures during the_ shift
>to' ensure that there were no accumulations of powder. This was not done.and,
.as' a' result of problems withlan inflatable seal and a ' gasket,_ powder g
Eaccumulated in the non-favorable' geometry enclosures. Subsequent to each of a
these events,;the licensee shut down the operation involved, began an
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_ investigation of the root'causes-of the events, and notified the NRC.
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^The Employee Concern Program at~ the. facility appears to be well established 1
tand adequate'to. address concerns of all the employees.
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1 Lo Within the scope of the inspection, two apparent. violations and two non-cited h
violations were identified. ' These included:
(Non-cited Violation) Failure to follow procedure for checking the u
- Ammonium Diuranate Pellet Line 3 bulk container enclosure for 4
accumulations'of powder.(Paragraph 2.a),
(Violation) Inadequate training of the Pellet Area operator such that the operator failed to realize that checking the Line 3 bulk container enclosure for accumulations of powder. was a criticality safety control (Paragraph 2.a).
'(Violation) Failure to follow procedure for checking the Ammonium
-Diuranate Conversion Line-5 Fitzmill enclosure for accumulations of
. powder (Paragraph 2.b), and.
(Non-cited Violation) Failure to perform semiannual load tests of hoists
.and chains or cables associated with bulk containers (Paragraph 3).
Art Inspector Followup. Item was also established to followup on the licensee's
- actions to ensure'that adaptive eyepieces are obtained before a person, needing such eyepieces, is allowed-to use a respirator (Paragraph 2.b).
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F REPORT DETAILS 1.
Persons Contacted Licensee Employees
. #R. Allen,' Manager, Integrated Fuel Burnable Assembly (IFBA) Facility
- J. Berry, Manager, Pelleting and Rods Area S. Deller, Manager, Human Resources
'*J. Fici,~ Plant Manager
'J. Fogg, Mechanical Engineer, Plant Systems Engineering, Technical Services
- D. Goldbach, Manager, Chemical Process Engineering
- W. Goodwin, Manager, Regulatory Affairs R. Henry, Process Engineer, Chemical Process Engineering, Technical Services
-J. Hooper, Safety Engineer, Regulatory Affairs
- *#E. Keelen, Manager, Fuel Manufacturing
- N. Kent, Nuclear Criticality Safety Engineer, Regulatory Affairs
- G. LaBruyere, Manager, Conversion Services
- S. Mcdonald, Manager, Technical Services R. Montgomery, Nuclear Criticality Safety Engineer, Regulatory Affairs
- D. Precht, Manager, Materials, Planning, and Service E. Quarterman, Process Engineer, Chemical Process Engineering, Technical Services
- E. Reitler, Manager, Regulatory Engineering, Regulatory Affairs L. Roebuck, Process Engineer, Chemical Process Engineering, Technical Services
- C. Sanders, Manager, Nuclear Materials Management & Product Records, Regulatory Affairs
- W. Ward, Manager, Uranium Recovery and Recycle Services
- D.: Williams, Nuclear Criticality Safety Engineer, Regulatory Affairs
- R. Williams, Technical-Coordinator, Regulatory Affairs Other licensee employees contacted during the inspection included electricians, mechanics, operators, security personnel and office personnel.
- Attended the exit interview'on August 20, 1993,
- Attended the exit interview on September 16, 1993.
2.
' Event Review (88005, 88010, 88015, 88020, 88025)
Condition S-1 of Special Nuclear Material (SNM) License Number 1107
. (SNM-1107) requires that licensed material be used in accordance with statements, representations, and conditions contained in Chapters 2, 3, and 4 of the' application dated March 26, 1984, and supplements thereto.
Chapter 2, Section 2.6 of. License SNM-1107 states that special nuclear material processing shall be conducted in accordance with approved -
written procedures or instructions.
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Chapter 3, Section 3.1.5.5 of License SNM-1107. states that training shall be provided by the Radiation Protection component or line Lmanagement to maintain a constant awareness by the employee of the necessity for radiation protection and nuclear _ criticality safety requirements and applicable portions of 10 CFR~ 19 and 20.
Section 3.1.5.7 states that line management shall be responsible for instructing personnel in the safety aspects of plant operations, including methods of dealing with process upsets or malfunctions.
During the inspection the inspector' reviewed the two most recent events involving nuclear criticality safety. They are outlined below, a.
Ammonium Diuranate (ADU) Pellet Line 3 Bulk Container Enclosure Chemical Operating Procedure, COP-820114, Automatic Feed Preparation System - Pellet Lines 1, 2, 3, and 4, Rev. 14, dated August 17, 1992, requires in Step 7.3.3 that the operator check for powder accumulation in the Bulk Container Room and down around the vibratory feeder at the end of the shift.
The operator is to notify the supervisor of any accumulation, and clean:up the powder per the supervisor's instructions.
This first event occurred in a pellet line which processes uranium dioxide ~ (U0 ) powder which has been produced by the ADV Process.
2 The licensee-has'a bulk container enclosure for each pellet line in operation. The enclosures are maintained as moderation control areas and are located six (6) feet above floor level.
During
. operation of the pellet line, a bulk container full of 1700 kilograms (kgs) of UO2 powder is placed in the enclosure and positioned over a support discharge chute by means of two alignment pins. On Line 3, the interface between the bulk container and the support discharge chute is. lined with an inflatable seal' which, when properly seated and inflated, acts to preve_nt powder from' escaping into the enclosure during discharge of the container.
The powder is discharged from the bulk container through.a' feeder device connected to the bottom of the container and flows through the discharge chute to a vibratory feeder located in the bottom of-the enclosure.
The powder is eventually fed into the pellet press.
On July 20, 1993, a pellet line operator discovered that a significant amount of UO powder had accumulated in the bottom of 2
the Pellet Line 3 bulk container enclosure, which is a non-favorable-geometry (NFG) enclosure.
When the powder was discovered, the operator notified his supervisor who stopped the operation and contacted the criticality safety. engineers.
A preliminary assessment indicated that a faulty or failed inflatable-seal between the bulk container and the feed.
system / discharge chute resulted in powder leaking into the enclosure. The licensee estimated that approximately 630 kgs of powder had accumulated in the bottom of the enclosure. When it w
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was determined that more than a minimum critical mass of 4.95 weight percent (wt%) enriched U02 powder had accumulated in the bottom of the enclosure, the licensee notified the NRC.
(A minimum critical mass involving this type of material would consist of approximately 42 kgs in spherical geometry with optimum moderation and full reflection.) Subsequently, an investigation team was formed to review the event and determine the root causes of the problem.
The investigation team identified various Causal Factors (components that influenced the course of the event) and.several Items of Note (significant deficiencies identified during the course of the investigation, which were not major contributors to the incident, but which the team determined should be addressed before the items have the opportunity to cause problems).
As a result of these Causal Factors and Items of Note identified by the investigation team, a second team was formed by the licensee to determine what corrective actions would be needed in order to l
restart the operations using the bulk containers and Pellet Line 3 (and Pellet Line 4 which is similar to Line 3). The corrective action team, which included members of the Pellet Area Quality Action Group, determined that certain actions would be needed prior to restarting Pellet Lines 3 and 4.
The following is -a listing of the Causal Factors which were noted by the investigation team and a listing of the corrective actions identified by the second team:
Causal Factor #1 - Large gaps existed around the feeder gasket which were caused by overtorquing.
Powder escaped through these gaps.
The root cause of the problem was i
identified by the team as less than adequate training.
Upon inspection of the feeder, the investigation team found that various gaps from one-eighth to one-quarter inch wide existed between the metal flange of the feeder and the gasket installed to prevent powder loss. The equipment drawings specified the metal flange on the feeder transition cone to be one-quarter inch thick. The team noted that the metal on the feeder transition cone was approximately one-sixteenth of an inch thick.
Because the metal was thin, overtorquing the bolts apparently crused the metal to buckle leaving gaps between the metal and the gasket.
Corrective Actions for Causal Factor #1:
1)
Generate a maintenance (PM) procedure for the feeder device, including torquing of the bolts.
2)
Revise the operations procedure (COP-814748) governing the feeder installation to require inspection of the feeder before installation on the container.
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Disposition the feeders for repair.or use.
4)
_ Purchase / install new transition cones or design /
fabricate / install reinforcing bars on the feeders.
5)
- Provide training for operators and maintenance
. personnel on the revised procedures.
6)
. Issue a Process Information Form (PIF) instructing the
- blending operators to install only rebuilt bulk container. feeders on containers going to Pellet Line 3 or Pellet Line 4.
The inspector verified.that a maintenance procedure had been
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completed that required annual-preventative maintenance on-
-the feeders. The inspector reviewed' procedure COP-814748, Installation and Removal of Feeder Valve Assembly, Rev.16, dated August 12,'1993, and verified that it had been revised and that: steps had been added to require operational safety inspections'of the feeders before they are installed on a e
m"m' bulk container.
The inspector also verified that new transition cones'had been installed on various feeders and these were the ones_ designated for use of Pellet Lines 3 and 4.
The training records were reviewed for those individuals who received training.on the revised procedure and.the use of the:PIF-The training appeared =to be adequate. The PIF,
. No. C-10958, Rev. A, dated August-13, 1993, was reviewed to ensure that it specified-which feeders could be used on Pellet Lines 3 and 4.
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' Causal-Factor #2 - Powder in the' bulk, container was off-balance, causing the container to shift off-center when 1
hoisted into the bulk container enclosure. This made it f.
more' difficult to. install' the container properly without
' damaging the inflatable seal. The root-cause of the problem E
- was identified by the team as less than adequate material handling.
The team found that bulk containers are sometimes released from the Bulk Blending arocess area with an uneven powder distribution inside. T11s problem is usually not discovered until the. pelleting. operators: have hoisted the container off the ground for installation in the enclosure.
Instead of returning!the containers to the Bulk Blending area to be -
balanced,'the-operators frequently just " manhandle" the containers, i
Corrective A' tions for Causal Factor #2:
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Revise COP-814748 and modify equipment to measure a 45
. degree' container tilt angle.
4 2)
Train the-Bulk Blending area operators on the revision-to COP-814748.
3)-
Revise'_ COP-820112 and COP-820114 to define and give instructions on measurement of tilt, better define A
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container handling, and define two-hour inspections of the enclosure for powder leaks.
4)
Train the Pellet area operators on COP-820112 and COP-820114.
T The inspector reviewed COP-814748 and verified that the requirement to measure a 45 degree tilt angle had been added.
(Following blending of the powder in the bulk containers, the containers were to be tilted first one way to a 45 degree angle and then the other way to a 45 degree angle in an effort to level out the powder in the containers.) The inspector also verified that a tilt angle measuring device had been added to the bulk containers.
The
. inspector also reviewed COP-820112, Bulk Handling / Hook-Up of Bulk Container at Pellet Line, Rev.11, dated August 6, 1993, and C0P-820114, Automatic Feed Preparation System -
Pellet Line 1, 2, 3, and 4, Rev. 15, dated August 6, 1993.
The procedures had been revised.to include instructions for checking the inflatable seal before installation of the container, insuring the alignment pins are retracted during installation of containers, and to check the enclosure for accumulation of powder every two hours by looking inside the access door in the bottom of the bulk container room.
The inspector also reviewed the training records of the r 11et area operators and the Bulk Blending area operators t.o ensure that they had received training in the appropriate procedure revisions.
Causal Factor #3 - The existing equipment in the bulk container enclosure was inadequate to allow operators to center and place the container properly without possibly damaging the seal and surrounding equipment. The root cause of the problem was identified by the team as poor workplace layout.
The team noted that a bulk container, when loaded with a maximum of 1700 kgs of powder, is very heavy and hard to maneuver inside the bulk container enclosure.
(The container, plus the powder inside weighs approximately 2900 kgs.) Operators must rely on a hoist and two guide pins to get the container centered in an enclosure that allows only minimal room for adjustment.
Because of this, the inflatable seals are sometimes damaged or the container is misaligned during installation. These problems can cause the seal to rupture during operation, Corrective Actions for Causal Factor #3:
No specific restart actions were identified for this item.
A long-term action item was to design / install upgrades to the current bulk container alignment system.
It was noted that the revised procedure, COP-820112, Rev. 15, requires
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that 2 operators be in the enclosure to assist in alignment of the bulk container during installation.
Causal' Factor #4 - The inflatable seal shifted at some point during installation, causing an overlap of the seal into the path of the butterfly valve in the feeder device.
The root causes of. the problem were determined by the team to be:
- 1) errors in installation were not detectable, and
- 2) procedures for installation of the container were followed incorrectly.
The investigation team determined that the feeder has a butterfly valve that is located directly above the F
inflatable seal when the container is installed in the enclosure..The butterfly valve requires air pressure to open and fails closed when pressure is lost.
The inflatable seal had apparently shifted out of position on July 19, and the' butterfly valve pinched a hole in the seal.
Corrective Actions for Causal Factor #4:
1)
Train Pellet area operators on the proper method of installing a bulk container in the enclosure.
2)
Revise COP-820112 and COP-820114 to include a powder leak check and add this check to the checklist.
The inspector reviewed the revised procedures and verified that they included a powder leak check and that this check was added to the' checklist. The training records of the Pellet area operators were also reviewed to verify that they had received training on the appropriate revisions and method to install a bulk container in the enclosure.
Causal Factor #5 - The only pressure switch on the system was located on the inlet side of the pressure regulator and could not' sense the pressure loss in the ruptured seal. The team determined that the root cause of the problem was less than adequate scope of the design - there were no engineered
. controls on the system to detect the loss of seal pressure.
The team found that the pressure switch was apparently installed to signal when air line pressure was-lost.
It is located on an 80 pounds per square inch (psi) air line, on the inlet side of a pressure regulator set to operate between 15 and 20 psi.
The pressure switch was set at 8 psi and was determined to be functional when tested following the event.
Corrective Actions for Causal Factor #5:
1)
. Verify electrical drawings match the equipment.
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Review existing pressure switch for applicability and use the switch if it proves to be adequate.
3)
Verify the pressure switch is interlocked to close the feeder valve.
4)
Update the drawings and equipment to reflect the changes made in the pressure switch to the seal side of the pressure regulator and addition of low pressure alarm.
5)
Change Numalogic for required interlocks and alarms.
6)
Install correct air line quick disconnects to feeders and air lines in bulk container enclosures.
The inspector reviewed. selected documentation which verified that the appropriate drawings had been updated and matched
'the equipment and the changes that had been made and that the required changes had been made in Numalogic.
The
' documentation of the functional test of the pressure switch was also reviewed. The inspector verified that the air line quick disconnects in the Pellet.Line 3 Bulk Container enclosure had been installed. Observation of selected feeders indicated that the quick disconnects had been installed as required.
Causal Factor #6 - The bulk container enclosure had no overflow drain to a favorable geometry container, therefore the spilled powder accumulated in an NFG container. The team determined that the root cause of the problem was less than adequate scope of the design - the enclosure was never designed to contain powder spills.
The team found that the bulk container enclosure is a large
" box" with a sunken rectangular area at the bottom.
Consequently, when the powder spilled it accumulated in the sunken section of the enclosure.
Corrective Actions for Causal Factor #6:
No specific restart actions were identified for this item.
A short-term action item was to design / install a favorable geometry powder collection system under the bulk container enclosure on Lines 3 and 4.with a level probe interlocked to shut down the process.
1 Causal Factor #7 --The second shift pellet line operator did not inspect the bulk container enclosure as required by procedure so the~ powder accumulation was not seen.
The team determined that the. root cause of the problem was that procedures.were followed incorrectly.
.The investigation team found that there had been a major power outage-just prior to the time the operator was going to inspect the enclosure.
Because of this upset condition,
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the operator was trying to recover and did not inspect the enclosure, assuming that there would not be powder inside.
He subsequently signed the log indicating that "0" kgs of powder were removed from the enclosure.
Corrective Actions for Causal Factor #7:
1)
Train-the Bulk Blending area operators on the revision to COP-814748.
F 2)
Train the Pellet area operators on the revisions to COP-820ll2 and COP-820114.
The inspector reviewed the training records of the Pellet area operators and the Bulk Blending area operators to ensure that they had received training in the appropriate procedure revisions.
Causal Factor #8 - The third shift pellet line operator inspected the enclosure and saw powder but did not recognize the significance of what she saw. The root cause of the-problem was identified by the team as less than adequate on-the-job training.
The team determined that this operator was not experienced with this equipment. She did inspect the enclosure and saw the " brown" inside but did not take any actions or notify anyone.
She apparently did not recognize what she was seeing or did not understand the significance of what was there.
Corrective Actions for Causal Factor #8:
1)
Train the Bulk Blending area operators on the revision to COP-814748.
2)
Train the Pellet area operators on the revisions to COP-820ll2 and COP-820114.
The inspector reviewed the training records of the Pellet area operators and the Bulk Blending area operators to ensure that they had received training in the appropriate procedure revisions.
During the investigation of the Line 3 Bulk Container event, the investigation team also identified the various Items of Note. The following is a listing of the Items of Note which were noted by
-the investigation team and'a listing of the corrective actions identified by the corrective actions team:
Item of Note #1 - The seals purchased were oval instead of round (the feeder connection is circular).
They were being stretched to fit the application. When the seals were originally ordered, the vendor did not make circular seals
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Therefore, the engineer specified oval seals instead.
This type of seal has been used for years at the facility.
Corrective Actions for Item of Note #1:
No restart actions were identified for this Item.
Item of Note #2 - MAPCON (the licensee's computerized maintenance tracking system) was set to reorder "0" seals when the quantity of seals in stock at the facility reached "0".
Corrective Actions for Item of Note #2:
1)
Install new seals when received.
The inspector reviewed the documentation that the MAPCON system had been revised to order the proper seals when the present supply reached "0".
Item of Note #3 - There is no routine maintenance or inspection performed on the bulk container feeders.
Upon inspection of the feeders, the team found that several were
.in need of repair or in need of new gaskets.
Corrective Actions for Item of Note #3:
The restart actions specified for this Item were:
- 1) inspect and repair the feeders and 2) install a reinforcement plate /bar to the' transition cone or purchase new transition cones.
The inspector verified that new transition cones had been installed on various feeders and these were the ones designated for use of Pellet Lines 3 and 4.
Item of Note #4 - The bulk container aligning pins in the enclosure are frequently not retracted during container installation.
Corrective Actions for Item of Note #4:
The restart actions specified for this Item were:
- 1) train the Pellet area operators and 2) revise the appropriate operating procedures concerning container installation.
The. inspector verified that the Pellet area operators had been trained on the correct procedures and that the i
procedures had been revised on installing the container in the enclosure.
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Item of Note' #5 A Procedural instructions. for-proper alignment of the bulk containers in-the enclosure are iinadequate and.there-are not procedural instructions.for the operators to' return the " unbalanced" containers. to the Bulk Blending area for. balancing.
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Corrective Actions for Item of Note #5 L
The restart actions specified for this Item were:
- 1) train
- the Pellet; area operators and 2) revise the appropriate r w lg operating procedures.concerning container installation.
The inspector verified that the Pellet area operators had'
- been trained;on the correct procedures and that the procedures had been revised to require that the containers e be returned to' the Bulk Blending area.for balancing if Trequired' 1"
-Item of Note #6 - So'me operators. appear to.be very V'
-frustrated over having.to wo'k under the existing conditions r
without having any input about those conditions.
-Corrective Action's for Item of Note #6:
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' Operators included in Root Cause Analysis and
.i 4-Corrective Action Item development teams.
"2)
Obtain operator input to procedure revisions /-
J improvements for Causal ~ Factor #2 startup actions.
A' review of the actions of the root cause. investigation team
'and the corrective action team indicated that the operators were either;directly-. involved-on the team or that their input was sought in development of the'.various items.
m Item of: Note ~#7 - A modification request'was in place to' c
- install:a. favorableL geometry drain section at the bottom of the-' enclosure, as' well as to correct other noted problems.
No' changes have been made to date.
Corrective' Actions for. Item'of Note #7
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.No, restart' actions were identified for this Item.
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- short-termicorrective action for= Causal Factor #6.
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- Item of Note #8 --Because' of the design and' orientation of -
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. the enclosure,'it.is difficult to determine if an i
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-clearly or:easilyLinto the rectangular sectio _n at the bottom
- ofJ the enclosure to determine if there is powder present.
- InLaddition, the lighting is poor inside the' enclosures.
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.g 11 Corrective Actions for Item of Note #8:
The restart actions specified for this Item were:
- 1) train the Pellet area operators and 2) revise the appropriate operating procedures concerning inspection of the enclosure.
The inspector verified that the Pellet area operators had been trained on the correct procedures and that the procedures had been revised to require a two-hour inspection of the enclosure. The operators were to use a flash light to make their inspection until better lighting can be installed.
Following the May,1991 General Electric Fuel Facility nuclear criticality safety (NCS) incident, the licensee formed a Criticality Safety Assessment Team (CSAT) and gave the team the charter to perform and document double contingency analyses for all fuel processing and handling operations in the facility.
Although the CSAT had analyzed the operations involved in the above event, the double contingency analysis had not been formally documented. Therefore, following the event, the Regulatory Affairs department analyzed the operation to determine NCS barriers for the purpose of. verifying that the double contingency principle had been met. The barriers which the licensee identified are as follows:
Barrier A: According to the licensee, one of the barriers which had been established for this operation was that of preventing an accumulation of more than a critical mass of material in the bulk container enclosure.
This was done by maintaining the integrity of the equipment (i.e. inflatable seals, proper operation of the system, etc.) and by routine inspection of the enclosure by the line operator.
(An active engineered control consisting of an interlock between seal pressure and the feeder valve which would shut on loss of seal pressure was found not to have been operable during this event.)
Barrier B: This barrier consisted of preventing a sufficient amount of moderator from entering the enclosure to cause a problem. The controls on this barrier consisted of maintaining the enclosure as a moderation control area, not having any sources of water inside the enclosure and having the enclosure elevated six feet off the floor.
On July 19, 1993, during the evening, an electrical storm in the area caused a power failure which affected the plant.
The pellet line operators were required to perform various functions in order to-bring the pellet lines back to full operation.
Due to these problems and an assumption that the bulk container had not been affected by the power failure, the second shift operator did not check for powder accumulation at the end of the shift. On July
4 12 20, 1993, the third shift operator, who was being trained to operate the equipment in the area, checked the enclosure for powder accumulation.
She noticed " brown" in the enclosure,.but did realize there was a problem and did not notify the supervisor.
As a result, the licensee lost criticality safety Barrier A but maintained Barrier B.
The licensee subsequently evaluated this event and determined that it was unlikely that sufficient moderator would be introduced or accumulated in the enclosure to cause a criticality problem.
In reviewing this event, the NRC agreed with the licensee that introduction and/or accumulation of sufficient moderator inside the bulk container enclosure was not
.likely to occur.
The. licensee was informed that failure of the operators to follow procedure was an apparent violation of License Condition S-1.
However,-this violation will not be subject to enforcement action because.the licensee's efforts in identifying and correcting the violation. meet the criteria specified in Section VII.B of the Enforcement Policy (NCV 70-1151/93-06-01).
During the inspections in August, the inspector reviewed the circumstances surrounding the actions of the operator on third shift, July 20, the day of the event. The operator had not been properly trained in how to perform an inspection of the enclosure and what to look for during the inspection. The operator also was apparently-not aware that' t's inspection of the bulk container 1
enclosure was a nuclear er-icality safety control used to ensure i
that an accumulation of a :, 'ficient amount of powder in the enclosure did not occur. Th L was again due to inadequate training. As a result, the operator failed to realize that powder was accumulating in the enclosure and failed to report the problem to-anyone.
Failure of line management to properly instruct the third shift operator to' maintain a constant awareness of the necessity-for radiation protection and nuclear criticality safety requirements and in the safety aspects of plant operations, including methods of dealing with process upsets or malfunctions was identified as an' apparent violation of License Condition S-1 (VIO 70-1151/93-06-02).
During a subsequent inspection performed during September 13-16,
.1993, the inspector determined that there was another problem related -to this event. The third shift operator needed glasses to see properly. -She had been assigned to the pellet area during the
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later part of June 1993 and:on July 7, 1993, had contacted the safety department'in order to obtain adaptive eyepieces for use
- inside'a respirator.
She then placed an order for the adaptive eyepieces with her optometrist but did not receive them until August 2,.1993.
During.the time from initial' assignment -to the pellet area -until August 2, she had been required, on occasion, to don a respirator and perform. work or make checks of the' status of equipment, including the bulk container enclosure.
The area supervisor was aware of the problem but allowed the operator to w
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13 continue to perform those duties. This problem was discussed at length with the licensee. The licensee indicated that there were no specific requirements regarding how good a person's eye sight must be in order to perform their job. That decision was left up to the individual.
The licensee indicated that they would evaluate this problem and take appropriate corrective action. The license.Cs actions in response to the problem of ensuring that
.adaptin eyepieces are obtained by those individuals needing them prior to performing work in a respirator will be tracked as an Inspector Followup Item (IFI) (IFI 70-1151/93-06-03).
b.
ADU Conversion Line 5 Fitzmill Enclosure Chemical Area Operating Procedure COP-811001, Fitzmill, Rev. 12, dated May 27, 1993, requires in Step 7.2.9 that the operator check for powder and water leaks several times a shift by looking throgh the lexan windows and/or by opening the mill enclosure doors.
COP-810901, Calcination Rev. 11, dated January 21, 1993, requires in Step 7.2.3 that the line operator take routine readings and
. record the data 'of all calciner and discharge system field instrumentation as per CF-81-015. CF-81-015, Conversion Field Data Checklist for TDC-2000 Conversion Line, Rev. 4, dated January 28, 1993, requires on page 3 of the checklist that the operator check for~ powder buildup inside enclosures (hoods) at the start of the shift and in the middle of the shift.
The licensee uses ADU Conversion Line 5 to process uranyl nitrate which is precipitated and the precipitate passed through an oil heater to reduce the moisture content to approximately 5 wt%.
From the heater, the material is then calcined to produce U0.
2 The UO that comes out of the calciner is passed through a feeder 2
system to a hopper and into a hammermill (Fitzmill). The feed hopper and Fitzmill are housed in.an enclosure to help reduce airborne problems that result from the dust that, at times, escapes the hammermill. The enclosure is located approximately four feet above the floor and measures approximately five feet wide by five feet deep by four feet high. Because hot material is being fed into the hammermill and because it spins at about 7,000 revolutions per minute, the mill must be cooled. This is accomplished by passing water through a cooling system surrounding the Fitzmill.
On August 13, 1993, at approximately 4 a.m., an ADU Conversion Area operator found that U02 powder had accumulated in the bottom, non-favorable geometry, cavity of the Line 5 Fitzmill enclosure.
The operator immediately notified his supervisor and the line was shutdown. An initial assessment of the problem indicated that a
-gasket between the hopper and the Fitzmill had failed allowing the powder to fall into the enclosure. Approximately 72 kgs of U0 2
.A 14 powder were rcooved from the enclosure. When it was determined that more than a minimum critical mass of 3.70 wt% enriched UO2 powder had accumulated in the bottom of the enclosure, the licensee notified the NRC.
(A minimum critical mass involving this type of material. would consist of approximately 60 kgs in spherical geometry with optimum moderation and full reflection.)
The NRC requested that the licensee not restart the line until the event was reviewed by the NRC and concurrence for restart was given.
The licensee agreed to this arrangement.
Subsequently, a root cause investigation team was formed to review the event and determine the cause(s) of the problem.
The investigation team identified various Causal Factors and several Items of Note during their investigation of the event. As a result of these Causal Factors and Items of Note identified by the investigation team, a second team was formed to determine what corrective actions would be needed in order to restart the operations using the Line 5 Fitzmill. The corrective action team, which included members of the Conversion Area Quality Action Group, determined what actions would be needed prior to restarting Conversion Line 5.
The following is a listing of the Causal Factors which were noted by the investigation team and a listing of the corrective actions identified by the second team:
Causal Factor #1 - There were inadequate mill enclosure inspections. The team decided that the instructions provided in the applicable procedures were not specific enough and the root cause of the problem was identified as incomplete procedures. Another root cause was identified as i
being less than adequate training in handling abnormal events.
Corrective Actions for Causal Factor #1:
Generate a Supplenental Operating Instruction (S0I) to require an inspection of the enclosure twice per shift. The i
S0I was to provide more detailed instructions on inspection methods (i.e. opening the enclosure doors and looking inside the enclosure as opposed to simply looking through the lexan windows [which are often coated with dust]).
The inspector reviewed the 501 and verified that it was used to revise Step 7.5.2 of COP-811001, Fitzmill, Rev. 12, dated May 27, 1993.
Step 7.5.2 required that the mill enclosure be inspected after every weekend shutdown for uranium powder build-up and that the powder be cleaned out. The operator was'to report the quantity of powder removed from the enclosure to the supervisor so he could record it in the Supervisory Log Book.
The 50I now requires that operators
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15
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inspect the ' enclosure twice per shift by opening the doors.
The guidance-also instructed the operators to look for powder accumulation and for water inside the enclosure. The operator was to notify the supervisor if powder accumulation p
exceeded one kg.
[,
Causal Factor #2 - Mill enclosures are non-favorable b-geometry and do not drain (to'a favorable geometry container).
The root cause of this problem was determined to be less than adequate design and scope because the mill L
enclosure was never designed to drain potential powder spills to a favorable geometry container.
Corrective Actions for Causal Factor #2:
No restart actions were identified.
However, in the long 1
term (within;12 months) the licensee plans to redesign the enclosure so that it drains to a favorable geometry container.
Casual Factor #3 - The gasket between the transition piece of the mill hopper and the mill head leaks.
The root cause of _this problem was identified as a lack of a preventive maintenance for this equipment, although no known previous history of gasket failures in this area had been noted.
A' contributing factor to the problem was found to be that two gaskets had been installed between the transition piece and U
the mill' head and the second gasket was only partially intact.
Corrective Actions for Causal Factor #3:
Inspect the gasket and replace it as needed.
(Thelicensee found that approximately twenty-five percent of the gasket was missing from one of the two gaskets.)
The inspector reviewed the maintenance work orders that had been initiated for this work. The documentation indicated that the gaskets on the other ADU Conversion lines were also checked but no other problems were noted. The licensee is considering other corrective actions including setting up a preventive maintenance program for the Fitzmill components.
Causal Factor #4 - The transition piece had cracks in the area where it was welded. The licensee noted, however, that the cracks in the' transition piece did not appear to go all u
the way through and probably did not contribute to the spill of powder into the Fitzmill enclosure. The root cause of i
this problem was_ identified as being that no equipment history was-kept'for this equipment. The investigation team noted that some equipment is permitted to operate without a preventive maintenance program in place to replace worn i
g, f
16 parts-that may have exceeded their service life.
Corrective Actions for Causal Factor #4:
Inspect the transition piece and repair / weld as necessary.
The other transition pieces on the other lines (except Line 2) were also inspected.
The inspector reviewed the maintenance work orders that had been initiated for this work. The documentation indicated that the transition pieces in all lines, except Line 2, had been inspected and were verified to'be in good condition or were repaired. No other problems were noted. The transition piece associated with the Line 2 Fitzmill is welded in place and will be inspected prior to restart of that line.
-J_ tem of Note #1 - Documentation of the weekly inspection results of the enclosure was being done through MAPCON; this differed from what was required by procedure.
The root cause of.this problem was identified as contradictory requirements in varying procedures. The MAPCON form required that some information about the inspection be recorded on the form while the operating procedure required that the inspection results be documented in the Supervisory
~ Log Book. The MAPCON forms were being filled out but no information was being recorded in the Supervisory Log Book.
Corrective Actions for Item of Note #1:
I Generate a.special form to log the inspections.
The inspector verified that these special forms had been generated. The forms were posted on all the enclosures of each Conversion Line and those on the lines in operation were being completed as required. Although the MAPCON form i
would still be generated and completed, the S0I instructed the operators to document the results of their inspections on a special form that was attached to the enclosure.
The special form required the operators to log the date, time, and shift of the inspection, the amount of powder, if any, that was removed from the enclosure, and required that the operator initial the form upon completion of the inspection.
Item of Note #2 - Fitzmills are not vented. The root cause 1
of this item was determined to be that the design input was not correct. The team indicated that the Fitzmills need to be vented to relieve pressure which can cause powder " blow-outs" at seals.
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Corrective Actions for Item of Note #2:
No restart or short-term corrective actions were identified for this item. 'As a long-term corrective action, the licensee plans to evaluate the feasibility of ventilating the mills.
. Item of Note #3 - Visual inspections are difficult to perform and powder build-ups difficult to quantify.
The root cause of this item was identified as less than adequate reach or visual envelope.
Inadequate lighting and equipment locations inside the mill enclosures make it difficult to see powder -accumulations.
Corrective Actions for Item of Note #3:
Provide more detailed instructions on how to inspect the enclosures and what to look for during the inspections.
' Tiie inspector verified that the SOI provided more
' instructions on how to inspect the enclosures and verified that the inspections were being completed and that any build-up of powder in the enclosures was being removed as
' required by the S0I.
Item of Note #4 - Twice a shift visual inspections required on CF-81-015 are not specific to clearly' identify the mill k
enclosure. The root cause of this item was determined to be an inconsi.stency between requirements.
CF-81-015 requires that 'the operator visually inspect for " powder build-ups inside enclosures (hoods)" twice a shift and enter data about what is present in a specified column.
However, the form does not specifically identify the Fitzmill enclosure for inspection.
Corrective Actions for Item of Note #4:
Clearly specify that the Fitzmill enclosures are to be inspected and give instructions on how the inspections are 0
-to be completed.
The inspector verified that the inspections were being
. completed as required.
The S0I clearly specified what to inspect and.how to perform the inspections.
Item of Note #5'- The 0-ring on the transition piece was found to be damaged. The root cause for this item was identified as_being less than adequate maintenance.
Corrective Actions for Item of Note #5:
.)
i i
18 Inspect the 0-ring on the transition piece of Line 5 was and replace it if necessary.
The inspector reviewed the maintenance work orders that had been initiated for this work.
The documentation indicated that the 0-rings in all lines, except Line 2, had been inspected and were verified to be in good condition or were replaced. No other problems were noted. The 0-ring associated with the Line 2 Fitzmill will be inspected prior to restart of that line.
Item of Note #6 - Gasket irregularities were noted on the i
gasket between the bottom of the chute and the top of the mill feed screw hopper. Two root causes were identified for i
this item. One being less than adequate preventive maintenance for the equipment and the other being procedures were incomplete (and did not require that this gasket be inspected during maintenance).
Corrective Actions for Item of Note #6:
No restart actions were identified for this item. The licensee indicated that the preventive maintenance program that they anticipate will be developed would include inspection of these gaskets.
Item of Note #7 - Moderator in the form of water and plastic are continually present in the mill enclosure. The root cause of this item was determined to be less than adequate control of design or field changes. The team noted this
]
problem because the cooling water for the mill head, milling chamber, and the mill shaft bearings runs to the cooling system through plastic (tygon) tubing.
Corrective Actions for Item of Note #7:
No restart actions were identified for this item. The licensee indicated that the preventive maintenance program that they anticipate will be developed would include inspection of these lines. The licensee was also considering evaluating the need for more durable tubing in
.this area.
Item of Note #8 - A review of the Fitzmill enclosure inspection completed-on July 23, 1993, indicated that 50 kgs of powder were removed from Line 4.
The root cause of this item was determined to be that this situation was not covered by procedure. The team noted that there are no instructions which inform the operators as to what quantity of powder is to be considered as excessive.
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Corrective Actions for Item of Note #8:
No restart actions were identified for this item. The team did determine that the operator who made this entry made a mistake and did not put a decimal point ir. the proper place.
.The operator intended to write "5.0 kgs" were removed but wrote down "50 kgs" instead.
Item of Note #9 - The team could not find any drawings of the equipment in the Fitzmill enclosure. The root cause of this items was identified as incomplete documentation.
p Corrective Actions for Item of Note #9:
p No restart actions were identified for this item.
The team did determine that no equipment drawings existed for the equipment inside the enclosure. The licensee is considering having drawings made.
The inspector _ asked to review the double contingency analysis performed for the Fitzmill and the enclosure. As was case for the previous event, the CSAT. had analyzed the operation of the equipment involved in the Fitzmill event but the double contingency analysis had not been formally documented. Therefore, following the event, the Regulatory Affairs department analyzed
'the operation to determine NCS barriers for the purpose of verifying that the double contingency principle had been met. The barriers which the licensee identified are' as follows:
Barrier A: According to the licensee, one of the barriers which had been established for this operation was that of preventing an accumulation'of more than a critical mass of material in the bulk container enclosure. This was done by maintaining the integrity of the components (i.e. the mill and the connections of the water lines, etc.)'and by routine inspection of the enclosure by the-line operator.
Barrier B: This barrier consisted of preventing a sufficient amount of moderator from entering the enclosure to cause a problem. The controls on this barrier consisted of:
- 1) visual checks of the enclosure and maintaining the E
integrity of the water lines against small leaks, and 2) the -
enclosure was not water tight (a passive engineered control) and.mainthining the integrity of water lines and connections against major breaks.
During third shift on Wednesday, August 11, 1993,'the ADU Conversion Line 5 Fitzmill enclosure was inspected and no powder accumulation.was noted at that time. However, during the next approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the enclosure was not inspected or checked for powder. accumulation. At approximately 4 a.m. on August 13, 1993, the third shift operator noted that the powder coming out of L
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20 the Line 5 product hood appeared to be darker than normal.
He then opened the enclosure doors, inspected the interior of the W
enclosure, and. noticed.an accumulation of powder in the bottom of the enclosure. The operator then notified his supervisor and the line was shutdown..An initial assessment indicated that powder was leaking.from a failed gasket. As a result of these problems, the licensee lost criticality safety Barrier A but maintained Barrier B.
The licensee evaluated this event and determined that it was unlikely that sufficient moderator would be accumulated in the enclosure to cause a criticality problem.
In reviewing this event, the NRC did not agree with the licensee.
Due to the possibility of catastrophic failure of the mill, introduction and accumulation of sufficient moderator inside ~ the bulk container enclosure was possible.
Following discussions between licensee representatives, Region II staff members, and NRC Headquarters personnel, the licensee was asked to reevaluate -the double contingency analysis for the operation of the Fitzmill.
Once the licensee was certain that they met the double contingency criteria, they would be allowed to restart ADV Conversion Line 5 operation.
The licensee completed all the restart actions and performed a reevaluation of the Line 5 operation with respect to the double contingency criteria. On August 23, 1993, the licensee initiated actions to restart the 4
Line 5 operation.
The licensee was informed that failure of the operators to follow
. rocedures was an apparent violation of License Condition S-1.
p The NRC determined that the licensee's corrective actions in response to the bulk container ' enclosure powder spill on July.20, 1993, should have included a review of other operations that could involve accumulation of powder if the operators were not aware of the importance of periodically checking enclosure conditions and were not performing the required checks or inspections. As a result, the criteria specified in Section VII.B of the Enforcement Policy were not satisfied (VIO 70-1151/93-06-04).
'Two cited violations and one non-cited violation were identified as specified above.
3.
Bulk Container Hoist Semiannual Load Testing (88015, 88020)
Condition-S-1 of Special Nuclear Material License Number 1107 (SNM-1107) requires that licensed material be used in accordance with statements, representations, and conditions contained in Chapters 2, 3, and 4 of the application dated March 26, 1984, and' supplements thereto.
Chapter 2, Section 2.2.13.9(5) of License SNM-1107 stipulates that bulk containers be designed, constructed, and tested in accordance with applicable specifications in Title 49, Code of Federal Regulations (CFR),~Part 178.251 and 178.252, for Specification 56 portable tanks.
is 3, 4 4
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R 21 Chapter 2, Section 2.2.13.9(7) of License SNM-1107 requires that semiannual' load tests be performed on the bulk container hoists and chains or cables, c
During the inspection and review of the July 20, 1993 criticality safety event, the inspector reviewed various requirements in the license application involving the bulk containers. As a result, the inspector reviewed the documentation of the design, construction, and testing of the bulk containers. No problems were noted with-these aspects of the bulk container usage. The documentation of the semiannual load testing results of the bulk container hoists and chains or cables were also reviewed. The inspector noted that the licensee's records indicated that the hoists and chains or cables had been load tested on January 31, F
and August 30, 1991, on January 27, 1992, and on June 23, 1993. The licensee could not locate any other load test records at that time.
/Therefore, it appeared that the load tests that should have been j
scheduled for mid-1992 and January of 1993 were apparently not performed. This issue was left as an Unresolved Item when the inspection was concluded on August 20, 1993, pending information on any other load test that may have been performed.
Subsequently, 'on. August 26, 1993, the licensee contacted the inspector and informed.him that the records had been located for those load tests U
which were performed on August 7, 1992, but no load tests had been performed in January 1993. The failure to perform the load tests was r
caused by.a-problem with scheduling the load tests so that it would not have a great impact on operations. This situation had been brought to
-the> attention of the. licensee by the vendor who normally performs the load tests. During the investigation of the powder spill in the ADU
- Pellet Line 3 bulk container enclosure, the investigation team apparently noted the problem with the load tests and also notified the cognizant' manager by a memorandum dated August 10, 1993.
In response to'this problem, the licensee initiated various corrective actions. The load tests have been placed into the MAPCON system and will be tracked and completed.
If the hoists are not made avaikble for load testing during the calendar month scheduled, the maintenance organization will tag the hoists "out of service" and operations will not be able to use' them until the load tests are completed.
The licensee was informed that failure to perform the load tests of the
- bulk container hoists and chains or cables semiannually as required was an apparent violation of License Condition S-1.
However, this violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B of the Enforcement Policy (NCV 70-1151/93-06-05).
One non-cited violation was identified.
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22 4.
Training (88010).
Because the two events discussed in Paragraph 2 above indicated that there were apparent weaknesses in the licensee's training program, the finspector reviewed the programs developed for training personnel in the ADU Conversion area, the ADU Pellet area, the Manufacturing Automation Project (MAP) area, and the programs used to train electricians and mechanical _ maintenance personnel.
Each area or group had developed their own specific training program.
~Before mid-1992, some of the areas / groups had designated trainers or other personnel who were typically responsible for ensuring that some type of training was performed. This generally was an additional assignment to the trainer's other job or duties.
In early 1993, the J
t licensee designated a training coordinator in each of the areas of ADV Conversion, ADU Pelleting,.and MAP.
(The other two groups already had specific individuals who were responsible for tracking training and
. setting up needed training.) The training coordinators and trainers or planners from all of the areas of the facility were then directed to s
meet weekly to coordinate their training efforts and develop a more consistent approach to facility training. A manager was appointed to be a mentor for the group and to help the various training coordinators and planners establish priorities and determine what training each area needed.
Some progress has been made.
Below is a table listing some of the common training program characteristics and how each training program has evolved to date.
I Program Conv.
Pellet MAP Elect.
Mech.
Characteristic Area Area Area Maint.
Retraining performed Yes Yes No*
No*
No*
approximately every 2 years Recertification of No No No No No
. qualified persons Training program No No Yes Yes Yes formalized with videos /
1 lectures / presentations
.l as part of qualification l
process Testing required to No No Yes Yes Yes demonstratejob/ skill i
has been mastered l
L
_Dn-the-job training used Yes Yes Yes No**
Yes
]
as a primary means to j
-train new/ transferred employees
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- 1. - 6 23 New person placed with Yes Yes Yes Yes Yes experience / qualified person l
Preliminary needs Yes Yes Yes No No analysis performed
- The trainers / supervisors indicated that, because the personnel in that area.are rotated through various jobs within that area on a routine 3
basis,~ retraining was not needed for the individuals to remain i
proficient in their jobs.
- Electricians who are hired at the facility are generally already qualified as journeymen or master electricians.
However, new employees are placed with an experienced person until they learn the site-specific aspects of the facility.
In the area of criticality safety training, the licensee had, in the past, given initial safety training for new employees and then biennial safety training including radiological control and criticality safety.
This initial training was typically given by Regulatory Affairs department personnel. Subsequent training was generally given by trainers or supervisors in each group or area as part of the biennial refresher. During March through July 1993, the licensee completed a series of reviews in criticality safety with those employees working in the chemical / radiologically controlled area of the facility.
During those training sessions, a questionnaire was passed out in an effort to determine the areas where more training was needed. Once the needs are determined, further training will be given and the results assessed by testing the participants. The licensee is trying to develop a performance based training program in the area of criticality safety training.
In reviewing training in general, it was noted that the programs established in the various areas are different but efforts are being made to coordinate the programs and standardize the training approach.
In the area of criticality safety training, all operators, electricians, and mechanics interviewed were aware of the specific need for proper spacing of containers of uranium powder'or waste, the. limitations on stacking containers of powder or waste, and other general criticality safety concerns. When asked whether or not checking an enclosure for an accumulation of. powder would be considered a criticality control, most readily agreed that it would be and all eventually agreed.
It was apparent that all _ personnel had reca
.y received refresher training in the general area of criticality cont e.
When asked if anyone had any suggestions for improving the training at the facility, most replied with ideas. The following is a listing of some of the suggestions mentioned:
fT
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_H' ave more frequent training' sessions - more often than every two years.
2):
Require recertification for operators.
3)
Have more trainers - at least one per shift.
4)
_ Required plant engineers to go out of the floor, observe-operations, and determine what improvements could be made - then have training on the improvements noted.
L 5)
' Allow a-longer period to train in the classroom and on the floor k
(0JT).ifneeded.
6)
Give a test to the operators / qualified personnel and use the results to determine the basis of the training that is needed.
7)
Have ongoing training ~in criticality control and have safety give on-the-spot quizzes to determine what people actually know about criticality. safety.
?No violations or deviations were identified.
.5.
E'mployee Concerns Program (TI 2500/028)
The inspector reviewed the program that the licensee'had established to address employee concerns. After reviewing the program and interviewing various licensee employees, including the Manager of Human Resources who oversees the~ program, the inspector concluded that the program was adequate to encourage the employees-to express-their-safety concerns without fear of retribution.
See the attached for further information.
'6.
Exit The scope and results of this followup inspection were summarized on
. August 20, 1993, with those persons indicated in Paragraph I above. The inspector described the issues reviewed and discussed in detail the inspection results and observations. No' dissenting comments were received from the licensee. Although proprietary material was reviewed and discussed during this inspection, proprietary information is not contained in.this report.
Item Number Description and Reference J M 70-1151/93-06-01 NCY - Failure of the operators to follow procedures for _ checking the ADV Pellet Line 3 bulk container enclosure for powder accumulation and notifying the supervisor (Paragraph 2.a).
70-1151/93-06-02 VIO - Inadequate training of a Pellet Area L
operator such that the operator failed to-realize that checking the Line 3 bulk container V
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25 l:lI enclosure for accumulation of powder was a criticality safety control.(Paragraph 2.a).
- 70;1151/93-06-03 IFI - Followup on the licensee's actions to ensure that adaptive eyepieces are.obtained before a person, who needs such eyepieces, is allowed to-use.a respirator (Paragraph 2.b).
70-1151/93-06-04 VIO. Failure of the' operators to follow procedures for checking the ADU Conversion
..i Line 5 Fitzmill enclosure for powder
~ ~ '
accumulation (Paragraph 2.b).
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70-1151/93-06-05 NCV - Failure to perform the semiannual load tests of the bulk container hoists and chains or y
cables as required (Paragraph 3).
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X, V m-s Attachment-As EMPLOYEE" CONCERNS PROGRAMS-
' Columbia Nuclear
- PLANT NANE: Fuel plant -. LICENSEE: Westirmhouse DOCKET '#: 70-1151 NOTE:.Please circle'yes or no if applicable and add comments in the ' space provided.
R A.
~PROGRAN:
9 1.-
D t.the licensee have an employee concerns program?
Ye g No/ Comments) m
-- 2.
Has NRC inspected the program?. Report # 70-115//93 -
B.'
SCOPE: (Circle. all that apply) 1.
Is.it for:
Technical? h No/ Comments) a..
b'.
~ Administrative?' h No/ Comments)
Personnel-issues? @ No/Connents).
c.
e &
1
.2.
D' Lit cover safety as well as non-safety issues?
i:
Ye E No/Connents) 3.
Is.it designed for:
Nuclear safety? h No/ Comments) a.-
Personal safety? h No/ Comments) b.-
c.
P onnel issues - including union grievances?
t es E No/ Comments).
q There is no union organization at this facility.
1 4.-.
D the program apply to all licensee employees?
Yes E No/ Comments)
~5.
-C actors?-
Yes E No/ Comments)'
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- Issue'Datet=07/29/93 A-1 2500/028 Attachment Ci.
f'-*
(
in 6.
Does the licensee require its contractors and their subs to have a r
ar program?
e g No/ Comments).
7.
Does the licensee conduct an exit interview upon terminating
_e oyees asking if they have any safety concerns?
E No/ Comments)
C.
INDEPENDENCE:
1.
What is the title of the person in charge?
Manager,' Human Resources 2.
Who do they report to?
' Plant Manager /'Ceneral Manager 3.
Are they independent of line management?
Yes 4.
Does the ECP,use third party consultants?
No 5.
How is a concern about a manager or vice president followed up?
l Through the licensee's Open Door Policy or Peer Review Program.
D.
RESOURCES:
1.
What.is.the size of the staff devoted to this program?
Four actively involved in employee relations, seventeen on staff.
' 2 '.
-What are ECP staff qualifications (technical training, interviewing training, investigator training,.other)?
Problem' Solving Investigations (i.e., EEO, Sexual harassment)
Counselling i
- E.
REFERRALS:
1.-
Who has followup on concerns (ECP staff, line management, other)?
Primarily the employee relations (ECP) staff, but it c5n be a joint effort including line management and upper management.
F.
CONFIDENTIALITY:
1.
Are the reports confidential?
-(Yes a No/ Comments)
They can be; it depends on what the employee wants. OSHA and EE0 concerns have been handled with confidentiality.
2500/028 Attachment A-2 Issue Date: 07/29/93 p
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w 2.g iWho is thelidentiity o'f the allegerimade.known to (senior management, '
a i
~
ECP staff,zline management, other)?-
(circle, if other exp1ain)
- Generally-the Mdnager Human Resources and Plant-Manager know the identity.
y r; W
- However,ythe person's identity'may.not be known to anyone; it depends on Jthe. situation' n
?3.e tcan employees be:
y 1 Anonymous? h No/ Comments).
'a.:
4
+
-Report by phone? h No/ Comments)_
~b.-
q LG.
FEEDBACK:'
s
~
1..
I eedback given to the alleger upon completion of the followup?
l es gr No -- If so,-- how?)-
' Always.
,y e
2..
Doesl program reward. good ideas?
^
ThelicenseelhasaQualityImprovementSuggestionprogramforthis.
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e' 3.-
Wh'o,;or, at what level, makes the final' decision of resolution?
)
'It depends on the. nature of the problem. The Plant Manager makes the=
^ dan final' decision.-
14 '.
'Are-the resolutions of' anonymous concerns. disseminated?
.Iffit is. required,uit.is desseminated.
If health and safety issues are involved,'the information.is-definitely disseminated.-
5;. "Are' resolutions of. valid concerns publicized (newsletter,
- bulletin board,.all hands meeting, other)?
i
_ Eyes. LAll.the'above means may be used depending.upon'the situation.
H..
-EFFECTIVENESS:-
J
- 1. -
.How does the: licensee measure the effectiveness of the program?
Periodic' communications, surveys, meetings with personnel, biennial customer service surveys.
2..
IAre' concerns:
' Trended?(YesgrhComments)-
~
- a..
4 sed?;horNo/ Comments) b.
U 4
3.
LIn'the last three years how many concerns were raised?'
o
'Of the concersn raised, how many were closed?
Whet pe_rcentage were' substantiated?
L.<
There1was;one ge'neral concern about making certain that everything:
," ^
waslbeing done correctly. Nothing specific.
pi KIssue Datei..07/29/93J
. A-3 2500/028 Attachment
- w. y.,
I 4
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c
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- ,n s
How are followup!techniqu's used to measure' effectiveness j
" ^f 4.'
e (random survey, interviews;Lother)?
j g
p On occasion,' random sampling is used to det
. how the Human j
Resources group is :doing including communict. ions with the employees and. employee concerns.
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5.
How frequently are internal audits of the ECP conducted and by i
i whom?
This is only done informally through the feedback that is received.
I.
ADNINISTRATION/ TRAINING:
'IsECPprescribedbyaprocedure?(jf)orNo/ Comments)
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t 2.
Howl are employees, as' well as contractors, made aware of this program (training, newsletter, bulletin board, other)?
9 New employee orientation addresses this and it is mentioned in the Employee Handbook that all employees receive.
It is also mentioned on bulletin boards.throughout the plant.
ADDITIONAL COMMENTS:
(Including characteristics which make the program especially effective, if any.)
The licensee feels that their program is effective because they do not keep receiving the same type of complaint over and over again.
The established program is effective because employees use it and are aware of it.
The Human Resources group solicit responses or input J
from all employees.. A culture of openness has been established at the facility. Also, the Human' Resources (ECP) staff know the employees and recognize changes in behavior if they occur.
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NANE:
- TITLE: -
PHONE #:
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- c. Bassett
/ Sr. Rad. Spec./ (404)331-55700 ATE CONPLETED: 8/20/93 2500/028' Attachment.
A Issue Date: 07/29/93 5
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