ML20059B903
| ML20059B903 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 12/17/1993 |
| From: | Bassett C, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059B894 | List: |
| References | |
| 70-1151-93-10, NUDOCS 9401040285 | |
| Download: ML20059B903 (16) | |
Text
I UNITED STATES
[pprs NUCLEAR REGULATORY COMMISSION p+'
~4 REGloN 11
(
101 MARIETTA STREET, N.W., SUITE 2900 5
ATLANTA, GEORGIA 30323-0199
)
/*
- Report No.:
70-1151/93-10
)
Licensee: Westinghouse Electric Corporation Commercial Nuclear Fuel Division Columbia, SC 29250 Docket No.: 70-1151 License No.: SNM-1107 Facility Name: Columbia Nuclear Fuel Plant Inspection Conducted: November 15-19, 1993 Inspector:
M
/
/
N C. H. Bassett, fuel Facility Project Inspector Date Signed
/
Approved by:
([
/
f f Ef J. McAlpin, Chief Dytefihned 4
Radiation Sa ety Projects Section
/
i Nuclear Mate ials Safety and Safeguards Division of Radiation Safety and Safeguards
{
SUMMARY
Scope:
i This routine, unannounced inspection involved a review of the actions the licensee has taken in response to the weaknesses noted during an NRC Operational Safety Assessment (0SA) which was conducted during August 1992.
l It also involved a review of corrective actions taken by the licensee in response to the violations identified in NRC Inspection Report (IR)
No. 70-1151/93-01. The OSA Report, IR No. 70-1151/92-04, was issued i
November 25, 1992, and NRC IR No. 70-1151/93-01 was issued March 9, 1993.
Results:
As a result of the inspection, twelve of the weaknesses identified during the OSA and six of the violstions identified in IR No. 70-1151/93-01 will be closed.
It was noted that the licensee has made progress in their efforts to correct weaknesses and deficiencies noted in their safety program; however, further actions are scheduled and needed.
Within the scope of the inspection, no violations or deviations were noted.
However, a Non-cited Violation (NCV) was identified for failure of Regulatory _
Engineering to review a TAF-500-1 form as required. Also, u Inspector Followup Item was established to followup on the licensee's efforts to revise and improve Procedure RA-104 (Paragraph 2.b).
i 9401040285 931217 PDR ADOCK 07001151 1
C PDR}
i
i REPORT DETAILS I
1.
Persons Contacted Licensee Employees
- J. Fici, Plant Manager
- R. Fuller, Plant Systems Engineer, Technical Services
- D. Goldbach, Manager, Chemical Process Engineering
- W. Goodwin, Manager, Regulatory Affairs
- J. Heath, Manager, Regulatory Operations J. Hooper, Safety Engineer, Regulatory Affairs
- E. Keelen, Manager, Fuel Manufacturing N. Kent, Nuclear Criticality Safety Engineer, Regulatory Affairs
- G. LaBruyere, Manager, Conversion Services t
- S. Mcdonald, Manager, Technical Services R. Montgomery, Nuclear Criticality Safety Engineer, Regulatory Affairs D. Parker, Acting Manager, Nuclear Materials Management & Product Records, Regulatory Affairs 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
- C. Wu, Advisory Engineer, Technical Services Other licensee employees contacted during the inspection included supervisors, operators, security personnel and office personnel.
- Attended the exit interview on November 19, 1993.
2.
Followup on Open Items (92701, 92702, 88005, 88010, 88015, 88020)
During the period of August 17-28, 1992, the NRC conducted an Operational Safety Assessment (0SA) of the licensce's safety-programs at the Commer cial Nuclear Fuel Plant in Columbia, South Carolina. The results of the OSA were documented in NRC Inspection Report (IR) No. 70-1151/92-04 dated November 25, 1992. The OSA. team noted a number of weaknesses and unresolved items whici' were identified by the designation of "92-04 "-
plus two more digits.
The last two digits indicated the numerical sequence of that issue as it appeared in the OSA report.
Following the OSA, the licensee issued a response, dated January 29, 1993, which outlined a Safety Margin Improvement Program (SMIP) and addressed various aspects of the facility safety program as a whole.
Subsequent to the OSA, an inspection was conducted during February 15-19, 1993, to followup on some of the weaknesses that had been identified as bahg violations of regulatory or license requirements. As a result, e:ght apparent violations were identified in NRC IR No. 70-1151/93-01, which was issued on March 9, 1993.
Because some of the violations were 1
7 2
)
being considered for escalated enforcement, a Notice of Violation was not issued until April 23, 1993. The licensee responded to the inspection report and Notice of Violation in a letter dated May 21, 1993, and detailed the corrective actions that had been taken or were planned to correct the problems identified.
During this inspection, the inspector reviewed fne actions taken by the licensee to address the OSA weaknesses and ccrrect the problems which resulted in the violations. These issues are discussed below and will be considered closed unless otherwise indicated.
a.
92-04 Lack of sufficient personnel to support all aspects of the programs in the Regulatory Affairs Department.
As a result of this weakness, the licensee reassigned the functions within the Regulatory Affairs organization and placed the criticality engineers in another section. This was done to allow more emphasis by one supervisor on criticality safety and by another supervisor on emergency preparedness, industrial hygiene, and chemical safety.
A technician was also assigned to assist the Nuclear Criticality Safety function. He immediately became involved with problems dealing with floor storage of filled and empty containers and with revising the criticality safety postir.g of storage areas and equipment. This individual later became involved with the revision of Procedure RA-104, " Regulatory Affairs Change Authorization."
The licensee also established an organization to plan and direct all improvement projects that would be initiated as a result of their Safety Margin Improvement Project (SMIP). The organization initially consisted of a Project Manager, a plant systems engineer, a regulatory engineer, and a configuration control technician.
Other support personnel now assist in this SMIP organization.
The inspector reviewed the reorganization of the Regulatory Affairs organization and the SMIP organization. The changes in the Regulatory Affairs organization appeared to be beneficial in directing more attention on criticality safety. The SHIP organization, which also serves as the focal point for the Configuration Control Program, appears to be directing the improvement projects in an organized and integrated manner.
b.
92-04 Failure of management to perform adequate reviews of technical documents. This item was also identified as a violation (VIO) in the NRC Inspection Report No. 70-1151/93-01. 93-01 VIO - Inadequate procedure caused by an inadequate review by management.
(OPEN)
Because various problems were noted in the area of adequacy of procedures during the 0SA, the licensee formed a WesTIP team, the j
Procedure System Improvement Team, to address the overall problem of-l
3 procedures and procedural improvement. The team met on various occasions to consider the problems and what could be done to correct the situation. The team completed its review on June 28, 1993,.and issued a report which outlined various recommendations. Although the initial project was completed, the licensee considers procedural improvement to be an ongoing process and the team will likely i
continue to meet and make further recommendations for upgrading the procedures.
Some of the initial recommendations that have been approved and implemented are as follows.
In the past, Operating Procedures were reviewed by various people and the Area Manager gave the final approval. The new system requires that a backup engineer, who is familiar with the equipment or operation, review and approve the procedure with input from operations personnel. This allows those who are most familiar with the operation to review the written procedure and correct any problems that may exist. Once this has been completed, the Area Manager then also approves the procedure and it is implemented. Other improvements include installing a cross-reference system on PRONET (the licensee's electronic procedure system) that allows an operator on the floor to review a procedure and any applicable Supplemental Operating Instructions (50Is) by using a computer terminal in the operations area.
In the past 501s were not on the PRONET system and an operator had to refer to a book kept in the area supervisor's office or the Control Room to review an 50I that pertained to a particular procedure.
The i
inspector reviewed the revised procedure review and approval system.
It appeared to be adequate to provide a better review of the procedures.
With respect to the specific violation cited and the specific procedure that was found to be deficient, the licensee revised the i
procedure, R0-06-003, " Ambient Environmental Air Monitoring for l
Radioactivity," and confirmed that no alpha activity calculations had been performed using the deficient procedure. The procedure had been revised before the OSA to update it and standardize the format.
The revision had inadvertently eliminated the self-absorption factor in the calculations for alpha activity.
In reviewing the problem, the licensee determined that, although the procedure had been revised to eliminate the self-absorption factor, the computer program which was used to perform the actual calculations had not been revised. Therefore, no erroneous calculations had been performed. The inspector reviewed the revised procedure and verified Qat the self-absorption factor had been re-incorporated into the formula for calculating alpha activity. Also, the i
inspector reviewed the licensee's actions to verify that no calculations had been made using the deficient procedure. The licensee's actions were adequate.
i This item will remain open because the licensee had committed to placing all the Regulator 3 Affairs (RA) procedures, including the Regulatory Operations (RO) procedures, on the Electronic Procedure
4 System (EPS). At the time of the inspection, all of the RA procedures had been placed on the EPS but only approximately sixty percent (60%) of the R0 procedures had been placed on the system.
This item will reviewed during a subsequent inspection.
c.
92-04 Lack of formal plant procedures.
(OPEN)
In response to this OSA weakness the licensee agreed to create administrative procedures for chemical safety and incorporate them into the Columbia Plant Safe Working Practices Handbook. This was to be done by December 31, 1993. At the time of this inspection, a draft administrative procedure had been developed but it had not been reviewed and approved. Therefore, this item will remain open and will be reviewed during a subsequent inspection.
The licensee also committed to develop a formal procedure for incident investigation by July 31, 1993.
In reviewing this item, the inspector noted that a procedure, RA-308, " Nuclear Criticality Safety Significant Incident Investigations," had been developed and issued for review on August 1, 1993. At the time of the inspection, the procedure had not been implemented but was in the review and approval cycle. The licensee indicated that the procedure should be implemented by at least the end of the year. The licensee also stated that, even though the procedure had not been implemented formally, the policy promulgated therein was being followed at the facility.
The licensee also committed to revise three other procedures by February 28, 1993. The inspector reviewed each of these procedures.
(1) RA-300, " Nuclear Criticality Safety Evaluations" RA-300, Revision (Rev) 2, had been reviwi and approved on February 26, 1993. The procedure incorporced guidance for evaluating potential accident scenarios.
It addressed double contingency requirements, process upsets or changes, barriers to prevent the upsets, and controls that support barriers in preventing or mitigating the consequences of an upset conditions.
The procedure also required that a structured and recognized safety analysis methodology be used to identify and assess all process upsets of nuclear criticality safety significance to the system being evaluated. The procedure appeared to be adequate.
(2)
RA-301, " Floor Storage of Special Nuclear Material" RA-301, Rev 7, had been revised and approved on February 26, 1993.
It was revised to delete the general authorization for the use of non-favorable geometry (NFG) containers. Another procedure was written to specify those movable NFG containers that had been approved for continued use in the Chemical Area of the facility. The procedure appeared to be adequate.
L 5
(3) RA-303, " Control of Moderating Materials for Nuclear Criticality Safety" RA-303, Rev 2, also had been revised and approved on February 26, 1993. The procedure was revised to stipulate that the only approved technique for fire fighting is a fog spray.
The procedure further requires that under no circumstances shall a direct concentration spray, jet, or beam of water be used to fight fires. The procedure appeared to be adequate.
c.
92-04 Lack of formal training in root cause analysis techniques for those who perform incident investigation.
As a result of this OSA weakness the licensee initiated training for selected employees. The training was begun in December 1992 and was given by a contractor using the Tap Root program for root cause analysis.
Subsequent training was provided by personnel from the Savannah River Site, again using their system for Root Cause Analysis. This training was given during February 2-3, 1993, and emphasized the areas of charting, coding, and making recommendations following completion of the investigation.
Seventeen people attended this training and, since that time, two individuals have participated as team leaders during the investigation of four separate incidents.
The inspector reviewed the training that had been given and determined that it appeared to be adequate. The inspector also reviewed the incident investigations that had been performed by the licensee using the root cause analysis training. At this Westinghouse facility, a team is formed to investigate an incident.
The team follows the process of charting and coding the problem to identify the root cause(s). This material is then given to a Quality Action Group (QAG) for further action. The QAG is generally made up of individuals who are very familiar with the process or area where the incident occurred. The QAG reviews the incident investigation findings and makes recommendations to management on actions to correct the problems that caused the incident. This process appeared to be effective and adequate.
d.
92-04 Lack of a functioning system to track and trend incidents, prioritize corrective actions, and formally close out issues and problems noted during investigations, assessments, and audits, and verify actions were completed.
(OPEN)
In response to this item, the licensee indicated that the PRONET Commitment Tracking System, managed by the Regulatory Affairs department, was being used to record all recommended corrective actions that were generated as a result of the Criticality Safety Assessments (CSAs) that were being performed. The licensee also indicated that a procedure was under development to formalize the-process for tracking and trending corrective actions in areas such as incident investigations, Criticality Safety Assessments, Safety I
i 6
Action Group surveillance items, and facility change control authorizations.
The procedure was to include a process.for assuring that the items identified were tracked to closure. A schedule for development of this procedure was to be included as part of the overall SMIP.
]
Upon reviewing the licensee's actions in response to this item, the inspector found that PRONET was being used to track items identified as a result of the CSAs. Other items were being tracked as well but it was not clear whether or not all recommendations and corrective actions were being tracked. The items identified during the CSAs were then assigned to the manager who had responsibility for the area involved.
Because this system proved to be rather slow in getting the problems addressed, the QAGs had been assigned to follow the items and take corrective actions. The QAGs then assigned each item to a particular individual as a task to be completed. The person was then responsible to study the problem, propose a resolution, develop a change request if necessary, and submit a Configuration Control Change form as well. The Configuration Control Change form, TAF-500-1, was the actual form that was being used to track and close out items. The changes and close out of items were being audited on a random basis.
The inspector noted that, although some items, corrective actions, and recommendations were being tracked, it was not apparent that all these were being tracked.
Specifically, the licensee had committed to develop a procedure to track and trend corrective actions from various sources. As of the date of the inspection, the licensee had not developed such a procedure.
In reviewing the SMIP, the inspector also determined that development of such a procedure had not been scheduled. During the week of the inspection, this project was assigned to an individual who indicated that the procedure would probably not be completed until next year.
Failure to develop a procedure to track items exemplified the licensee's weakness in this area and the need for such a procedure.
e.
92-04 Human factors problems associated with the Electronic Procedure System (EPS).
(OPEN) i The licensee initiated a review of the area of human factors and the improvements that could be made. The review, which was completed June 28, 1993, involved input from a team and from questionnaires given to the operators and other personnel on the production floor.
As a result of the efforts of the team and the input from operators, the licensee has planned various short-term and long-term actions.
One short-term action involves installation of additional computer terminals on the ADU Rod lines so that the terminals would be available to the loader and welder on each line. The projected completion date for this item was December 31, 1993. Many employees requested capabilities of the EPS which were not possible. Requests included color terminals at each work station and being able to view an entire page of text on one screen.
7 The licensee is considering other improvements in this area.
For the coming year, the licensee plans to convert the dumb terminals in the Chemical Area to Personal Computer (PC) terminals with the capability to access the PRONET system. This will provide the operators numerous capabilities that are not currently available.
Some of the advantages will include:
(1) the ability to view graphics associated with various procedures on the PC monitor, (2) the ability to have upper and lower case letters used in the procedures that appear on the screen (currently the EPS can only show upper case), and (3) the ability to print a procedure at a specified location such as the supervisor's office. Other long-term improvements under consideration include format changes, full page screen, and scrolling / find capabilities.
As noted above, this item will remain open pending completion of the improvements contemplated for this area of human factors. These improvements will be reviewed during subsequent inspections, f.
92-04 Inadequate control and implementation of Supplemental Operating Instructions (S01s).
93-01 VIO - Multiple examples of failure to follow approved procedures for control and implementation of the SOI program.
(OPEN)
As noted in Paragraph 2.b above, various problems were noted in the area of adequacy of procedures during the OSA. The licensee subsequently formed a WesTIP team to address the overall problem of procedures and procedural improvement. The team completed its i
review on June 28, 1993, and issued a report which outlined various recommendations. Although the initial project was completed, the licensee considers procedural improvement to be an ongoing process and the team will likely continue to meet and make further t
recommendations for upgrading the procedures.
With respect to the S0I program, the licensee has completed various actions to correct the problems noted during the OSA. The main implementing procedure, TA-005, "S0I and PIF Preparation and Distribution," was revised and approved on May 13, 1993. The major modification of the procedure involved clarification of what an S01 could be issued for and how long it could remain in effect. Another major action was to cross-reference the S01s with the applicable operating procedures.
All of the 501s were placed on the EPS and the operators now have access to them via the computer terminals in their areas.
This improvement has also provided for improved procedure control and accountability. When operators acknowledge that they have read an SOI, it is recorded electronically and the files are updated automatically. Thus, a supervisor can ensure that all employees have read the procedures and the applicable S0I(s) as required before they are assigned to work on a specific job.
One improvement item that the licensee committed to develop was an audit process to evaluate overall system effectiveness. The licensee indicated that this referred to the S0I program as it
i 8
existed before the 501s were placed on the EPS. The licensee did perform an audit of S0I conformance during May 1993. Although a few minor discrepancies were noted as a result of the audit, the licensee concluded that the problems had been corrected. With the S01s available on the EPS, the licensee indicated that an audit process was no longer necessary. The inspector reviewed the audit that had been performed and concluded that it was adequate and did indicate that the problems noted during the OSA had been corrected.
With respect to the specific violation cited, the inspector verified that the licensee had taken the actions outlined in their response.
The specific conditions which violated the licensee's procedures had been corrected, i.e. the operators had reviewed the S01s, the S0Is were placed in the appropriate books or removed from the book, and the S01s Acknowledgement Sheets were reviewed as required.
- Later, the implementing procedure, TA-005, had been revised, the SOIs had been placed on the EPS, and the S0Is were cross-referenced with the applicable operating procedures. Also, an audit had been conducted by the licensee which showed that only minor discrepancies existed in the system. Through a review of the records and the EPS, the inspector verified that the operating procedures contained cross-reference information to the 501s and that this was readily apparent for the operators.
Because there are various procedural improvements still pending, this item will remain open and will be reviewed during subsequent i
inspections.
g.
92-04 Lack of special training for Process Engineers in criticality safety to enable them to make equipment changes by substitution.
The OSA report indicated that Process Engineers were permitted to make equipment changes-in-kind, as well as changes by substitution, without obtaining the approval of the engineers in Regulatory Affairs. The report stated that the Process Engineers had not been specifically trained to make changes by substitution.
In the licensee's response to the OSA, which was dated January 29, 1993, the licensee indicated that the Configuration Control program had been modified to delete the authorization for Process Engineers to make such changes. When the inspector reviewed the procedure implementing the Configuration Control program, it was noted that the procedure had not been revised, approved, and implemented following the_0SA to delete such authority until April 22, 1993.
When asked about this apparent discrepancy the licensee indicated that the Configuration Control program had initially be modified by a letter and then subsequently by changing the procedure, The inspector reviewed the letter, dated December 16, 1992, from the Manager of Process Engineering which was written to other managers.
It stated that, as of the date of the letter, parts replacement by i
9 substitution must have documented verbal approval by Regulatory Engineering. The copies of such documentation were to be sent to Regulatory Engineering and to Process Engineering, as well as the Area Manager. The licensee indicated that this policy was
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implemented via a letter to make it effective as soon as possible and that the procedure change, which is a slower, more deliberate process, was then initiated.
The inspector reviewed the Configuration Control forms that documented the review of changes by substitution by Regulatory Engineering. Those forms, TAF-500-1, " Chemical Manufacturing System Configuration Change Form," with issuance dates from January through April 1993 were reviewed. Of the approximately twenty forms which indicated that a change by substitution was required, only one was noted that did not have the review and approval of Regulatory Engineering required by the letter. When the licensee reviewed this problem, no documentation of any verbal approval by Regulatory i
Engineering could be found. However, the licensee did find that a similar problem had been written up as a Red Book item (i.e., an item needing immediate attention) in December 1992 and the 4
corrective action was the same one recommended on the unreviewed i
TAF-500-1 form. The Red Book item had been corrected by the same method as the problem mentioned on the unreviewed form and the Red Book item had been reviewed by Regulatory Engineering in May of
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1993. The inspector also noted that the TAF-500-1 forms were I
subsequently revised to delete any reference to " change by substitution" as an option of Change Type on the form and to require j
a review by Regulatory Engineering. This NRC identified violation is not being cited because criteria specified in Section VII.B of the NRC Enforcement Policy were satisfied (NCV 70-1151/93-10-01).
h.
92-04 Lack of descriptions of accident scenarios that were considered during Criticality Safety Assessments.
As a corrective. actions to this weakness, the licensee developed a new procedure and investigated which formal accident scenario evaluation technique to use. The procedure that was developed, RA-307, " Nuclear Criticality Safety Assessments," Rev 0 was implemented on February 26, 1993. The procedure documents the steps to be used to develop a criticality safety assessment.
It directs the Nuclear Criticality Safety engineers to perform a Nuclear Criticality Safety Evaluation in accordance with Procedure RA-300. That procedure requires a review of all applicable accident scenarios. The inspector reviewed RA-307 and determined that it appeared to be 4
adequate.
After reviewing the various methods available for formal investigation / evaluation of a problem or incident, the licensee chose the Hazard and Operability (HAZ0P) Analysis methodology for use at the facility. To fulfill their commitment to the NRC and to comply with the requirements specified in 29 CFR 1910.119, Process Hazard Analyses (PHA) and HAZOP Analysis training was conducted
- j 10 during May 3-6, in PHA techniques. A total of approximately fifteen people attended the HAZOP training and approximately thirteen licensee personnel participated in the PHA training. The inspector reviewed the training that was provided by a contractor.
It appeared to be adequate.
i.
92-04 Lack of information in the Nuclear Criticality Safety Evaluations (NCSEs) regarding reference drawings, assessment of accident scenarios, independent reviews and limits, and controls.
93-01 VIO - Failure to comply with the license application and r
with procedural requirements regarding the preparation of NCSEs.
During the OSA, reviews of Regulatory Affairs Review (Change)
Requests indicated that the licensee had not considered and/or included descriptions of accident scenarios for various change requests that had been processed. Other required information was also apparently not included in the documentation. As a result, the licensee totally revised their procedure governing change requests.
RA-104, " Change Authorizations," (originally entitled " Regulatory Affairs Review Request") was reviewed and implemented on February 26, 1993. The inspector reviewed the revision and determined that it appeared to be adequate. The procedure required a person originating a change to submit various items for review by a Regulatory Affairs engineer. The originator was to provide:
(1) a configuration control change form, (2) a detailed description of the system to be changed /added, (3) marked-up drawings to supplement the process description, (4) a listing of all available equipment and process specifications, (5) a description of how the system was supposed to work under normal operations and as a result of potential process upsets, an.1 (6) a review of the license safety demonstration as needed.
The licensee found that this procedure, as it was initially revised, proved to be cumbersome and typically required a great deal of time for the change request / review / approval process.
(It was estimated that the entire' process would take up-to 900 days in some complicated cases.) Consequently, a WesTIP team was formed to evaluate the procedure and make recommendations on ways to maintain safety but also speed the process. As of the date of the inspection, the team was still in the process of determining what could be done and the procedure is likely to be revised again. The licensee was informed that their actions to revise Procedure RA-104 would_ be an Inspector Followup Item and would be reviewed during a subsequent inspection (IFI 70-1151/93-10-02).
The licensee also revised procedure RA-300,
" Nuclear Criticality Safety Evaluations". This procedure was reviewed and appeared to be adequate.
(Refer to Paragraph 2.b).
i Regarding the specific violation cited, two examples of inadequate facility change requests were noted. As corrective action, the licensee performed remedial Nuclear Safety Analyses for each. The t
h 11 remedial analyses were performed by a qualified criticality safety engineer and reviewed by the Manager, Nuclear Materials Management and Product Records, Regulatory Affairs. The inspector reviewed these analyses which appeared to be adequate.
r j.
92-04 Transfers were being made from favorable geometry l
containers to NFG containers solely on the basis of chemistry analyses results that were transmitted orally by telephone and were not verified. 93-01 Failure to follow the license application stipulating verification of Uranium-235 concentration and free acid.
t content prior to transferring solutions from the adjustment tanks to the uranyl nitrate storage tanks.
The practice noted in the OSA was replaced following the assessment.
The licensee initially set up a telephone notification system which required Uranium Recycle and Recovery Services (URRS) personnel to call the Health Physics (HP) laboratory. A call was to be made at least once each working day to verify all the U-235 and free acid content results previously phoned-in during that day.
The phone call practice was revised in March 1993 and has been functioning since that date. A local area network (LAN) system was set up for controlling sample results. When a sample is taken by URRS personnel, it is logged into the computer along with the i
type (s) of analysis (es) required. The computer system then assigns a sequential log number to the sample. After the sample has been analyzed by HP Laboratory personnel, the results are logged into the computer system. URRS personnel then view the sample results on the computer in their area.
If a sample has not been analyzed when the system is queried by URRS, the sample number is displayed but no results are listed. The system is set up to calculate concentration and check the results to determine if they are within acceptable limits. An analogous system has been established for controlling the free acid content results.
The inspector observed the functioning of the system and verified that it operated as outlined. The inspector questioned HP Lab t
technicians and URRS operators and verified that they knew what their respective duties were and how the system operated. The system appeared to be adequate to prevent the use of unverified measurement results.
l t
k.
92-04 Inappropriate, contradictory, or unclear postings 1
regarding criticality controls. 93-01 VIO - Failure to follow procedures for posting criticality signs.
l In response to this OSA weakness and the subsequent _ violation, the
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licensee indicated that they would implement enhanced controls and programs in two phases.
(These two phases were also to be used to address the problems noted in the OSA weaknesses 92-04-19 and 92-04-21.) During each phase a separate team was to be formed to address the problem. The first team was to concentrate on the v
i 12 l
problem of postings and the second team was to concentrate on the problem of floor storage of Special Nuclear Material (SNM). The teams were to complete their activities by June 30, 1993.
The inspector reviewed the actions taken by the licensee. Although the licensee indicated that two teams would be formed, in reality only one team was formed to address these issues. The " team" consisted of a team leader from Regulatory Affairs who received assistance from teams of individuals from various areas including supervisors, area trainers, and operators who worked in the areas.
Teams were organized in the Ammonium Diuranate (ADU) Conversion area, URRS area, the Rod and Pellet area, the Manufacturing Automation Project (MAP) area, and the Integrated Fuel Burnable Assembly (IFBA) area. The teams first addressed the floor storage problem and then the posting problem. Team meetings began in February 1993 and continued until May. During the process, each area team generated a list of recommendations on issues that needed to be reviewed and/or corrected. The various teams identified the types of materials stored in the areas and the containers used/needed.
Postings and labeling of the containers and postings i
for storage areas were reviewed and problems identified.
Storage areas requirements were reviewed for full, partially filled, and empty containers. Areas where waste containers (5-gallon buckets) were to be maintained were to be indicated by a red painted perimeter with a black circle placed where the container would be located.
Exclusion zones were reviewed to ensure that they were properly located and designated.
All postings in the facility were reviewed and new postings generated.
New area and container postings were subsequently installed and training was given on the new postings. The new postings were neon pink in color to distinguish them from the old postings which had been yellow with black print. The postings were also changed to simplify them and make them more understandable and more consistent throughout the facility.
By the end of the project, more than 2,000 new postings / signs had been installed.
The inspector reviewed the postings that had been installed by the licensee. They appeared to be placed properly and to contain i
adequate information. The inspector also toured the entire facility i
to review the corrective actions taken to replace or correct the
'l signs / postings that had been noted during the OSA, provide for i
proper types of containers in storage racks, or maintain proper spacing.
Signs had been posted at the Rod Reclamation Hood and the Tray El evator.
No improper containers were noted in the Rotary Blender Area. During a tour of the facility, observation of the various areas did not reveal any material stored in improper or disallowed containers.
Passive engineered controls (a metal bar welded in place and a strip of angle iron bolted to the floor) to preclude spacing problems were noted to have been installed in the area where
f 13 drums containing SNM standards were stored.
Signs were posted in the Rod and Pellet area which prohibited double-stacking of pellet pans in the pan storage areas.
k.
92-04 Inconsistent application and use of the licensee's yellow painted exclusion zones in the production area.
93-01 VIO -
Failure to follow procedures concerning compliance with posted criticality signs and " Surface Density" areas.
The licensee's general actions in response to this weakness are discussed in Paragraph 2.j above.
The specific corrective actions taken by the licensee in response to the violation were reviewed by the inspector. The work table noted in the OSA was fitted with passive engineered controls to preclude placement of items into the tank's exclusion zone, the area on the floor around the tank which was painted yellow. The controls consisted of pieces of stainless steel metal in the shape of an inverted-V which were bolted in place on the top and the lower shelf of the table. This appeared to be adequate to maintain the integrity of the tank's exclusion zone.
i Additionally, the inspector toured the facility and did not note any further examples whe;e a piece of equipment had an exclusion zone which extended into a working space. Many areas which had formerly 1
been painted yellow had been repainted.
It appeared that only safety exclusion zones remained painted yellow.
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1.
92-04 Inadequate control of non-favorable geometry containers throughout the plant. 93-01 VIO - Failure to comply with the license application requirements related to the use of non-favorable geometry containers.
Many of the licensee's corrective actions have been discussed previously in other inspection reports. NRC Inspection Report Nos. 70-1151/92-09, 70-1151/93-01, and 70-1151/93-03 discuss various aspects of the actions taken to correct the problems noted with movable NFG containers. Those reports addressed the licensee's actions:
(1) to form a multidisciplinary team to review the NFG issue and make recommendations for controlling the use of such containers, (2) to conduct an inventory of movable NFG containers in the Chemical Area, (3) to remove all unnecessary containers, (4) to perform additional training for using and controlling NFG containers, (5) to implement a new procedure, RA-306, for controlling NFG containers, (6) to perform Nuclear Safety Analyses
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for all the NFG containers that were to remain in use in the facility, and (7) to revise the applicable procedures to incorporate I
the necessary changes for using NFG containers.
l; During this inspection the inspector reviewed the remaining actions that the licensee had taken. The inspector reviewed selected procedures that had been revised subsequent to the implementation of RA-306 and verified that the procedures reflected the controls specified in the new procedure.
1 14 In response to the violation cited, the first portion dealt with a sump in the diked area underneath the uranyl nitrate storage tanks.
The licensee had reduced the size of the sump to a favorable geometry and had performed a fault tree analysis for the original sump. The inspector verified that the sump had been reduced to a favorable geometry by direct observation. Also, the inspector reviewed the fault tree analysis for the original sump.
It appeared to be adequate.
A second part of the violation dealing with NFG containers referred in large part to the use of 55-gallon drums throughout the Chemical Area. The aforementioned actions were generally directed at correcting this problem. The licensee did perform a fault tree analysis for the original condition which included the use of 55-
-l gallon drums. The inspector reviewed the analysis and concluded that it appeared to be adequate.
1.
92-04 Lack of engineering controls or inadequate engineering controls for the storage of SNM. Another example of 93-01 ;
VIO - Failure to follow procedures concerning compliance with posted-
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criticality signs and " Surface Density" areas.
The licensee's general actions in response to this weakness are discussed in Paragraph 2.j above. The specific corrective actions taken by the licensee in response to the violation were reviewed by the inspector and are also discussed in Paragraph 2.j above.
m.
92-04 There was no mechanism developed to provide an immediate and continuous assessment of the radiation levels at the Central Alarm Station in the event of a criticality emergency.
In response to this 05A weakness, the licensee provided a survey instrument for use by the security personnel at the Central Alarm station. Also, the contractor security personnel, as well as the licensee's Manager of Security, were trained to use instrument in-case of an emergency. The inspector reviewed the documentation of the training that had been given to the guards during January 1993.
The inspector also interviewed various guards and determined that they could use the survey meter and knew what to do in case of a criticality emergency. The licensee's actions appeared to be adequate.
i 3.
Followup on Noncompliances (92702) 93-03 VIO - Using an unapproved procedure i
During the inspection which was' conducted during February 15-19, 1993, to j
followup on some of the weaknesses that had been identified as being violations of regulatory or license requirements, one other violation was 1
identified which was not related to the OSA.
The violation dealt with the use of a form which was referenced in Procedure RA-108, " Safety Significant Interlocks." The form, RA-109-1, was a portion of a 1
m s
15 procedure that had not been approved, RA-109, " Safety Significant Interlock Test Documentation."
To correct this problem, the licensee transferred the forms that were previously contained in the unapproved procedure, RA-109, to an existing procedure, RA-108. RA-108, was subsequently revised to delete the reference to RA-109 and the forms were renamed and the entire package was review and approved. The inspector reviewed the current procedure, RA-108, Rev 3, dated August 5, 1993, and verified that the references to RA-109 had been removed. The inspector also verified that the forms used in the former RA-109 had been renamed and that they were now incorporated into RA-108.
l Another action that the licensee indicated would be taken was to enter all the Regulatory Affairs (RA) procedures into the PRONET document control system. The inspector verified that the RA procedures had been entered into the PRONET system. This items is considered closed.
l i
4.
Exit Interview The scope and results of this followup inspection were summarized on November 19, 1993, with those persons indicated in Paragraph 1 above.
i 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 i
contained in this report.
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Item Number Descriotion and Reference 70-1151/93-10-01 NCY - Failure of Regulatory Engineering to 1
review a TAF-500-1 form as required (Paragraph 2.g).
70-1151/93-10-02 IFI - Followup on the licensee's actions to revise Procedure RA-104 (Paragraph 2.1).