ML20127G665

Insp Rept 70-1201/92-09 on 921207-11.No Violations Noted. Major Areas Inspected:Mgt Controls,Training,Nuclear Criticality Safety,Operations & Maint & Surveillance Testing

ML20127G665
Person / Time
Site:	07001201
Issue date:	01/08/1993
From:	Kasnicki D, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127G664	List: ML20127G658 ML20127G665
References
70-1201-92-09, 70-1201-92-9, NUDOCS 9301220034
Download: ML20127G665 (7)

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Report No.: 70-1201/92-09 Licensee: B&W Fuel Company Commercial Nuclear Fuel Plant Lynchburg, VA 24505 Docket Nos.: 70-1201 License No.: SNH-ll68 Facility Name: Commercial Nuclear Fuel Plant (CNFP)

Inspection Conducted: -Dece er 7-11,1992 /

Inspector: NA

,4 wi 'l D Date Signed D. KasnickicFtieT F Ality(Projectinspector Approved by: s /!&!f3 Dhte Signed Y E Ra.diation McAlptff6, Chief Safety f Project Section Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards 1

SUMMARY

Scope:

This routine, unannounced inspection involved management controls, training, nuclear criticality safety (NCS), operations, and maintenance and surveillance testing. More specifically, the following items were inspected: adequacy'of NCS and general safety as indicated by performance in the following programmatic areas: the identification and reporting of unusual NCS incidents; the identification of 10 CFR 21 reportable items; safety organization structure; safety committee activity; radiation worker training; '

internal NCS audits; criticality monitoring system functional testing and-calibration; preoperational audits of changes; fuel handling and storage; chemical storage; implementation of new. fuel handling limits for up to 5.1 percent enrichment. Licensee action, if appropriate, on two NRC Information Notices (ins) was also followed up on.

Results:

In the areas inspected, violations or deviations were not identified. The licensee's -implementation of the program inspected and the controls to assure safety and compliance with specific license requirements were acceptable. No observations were made of any circumstances which would preclude or otherwise hinder safety. There were no safety organizational or staffing changes and records of Safety-Review Board meetings indicated adequacy in meeting related requirements. Records indicated that radiation worker training was conducted as required. Internal NCS audits met requirements and required criticality 9301220034 930108 PDR ADOCK 07001201

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2 alarm system calibration and testing had been performed. There had been no f1CS related preoperational audits of changes. Fuel handling and storage was in compliance with requirements and chemical storage vas improved significantly with a new chemical storage building. There had been no 10 CFR 21 reportable items. The licensee had received and taken appropriate action on two IIRC Ifis. There had two non-reportable f1CS incidents which appeared to have been resolved adequately. tiew fuel handling limits for higher enrichment had not yet been implemented but a review of planned implementation methods appeared adequate.

REPORT DETAILS

1. Persons Contacted Licensee Employees

• C. Carr, CNFP Plant Manager  :

• G. Carter, Supervisor, Fuel Manufacturing

• S. Godsey, Supervisor, Fuel Rod Loading

• 0. Gordon, Senior Health Physicist

• K. Knapp, Manager, Safety and Licensing -l l

Other licensee employees contacted during this inspection included I craftsmen, engineers, operators, mechanics, security force members,- '

technicians, and administrative personnel.

• Attended exit interview.

2. Organizational Structure (88005)

Section 2.1.1 of the license application defines the structure of_ the Commercial Nuclear Fuel Plant (CNFP) safety organization. Discussion with a CNFP representative indicated that no changes have occurred-to the structure or staffing of the safety organization since-the last Fuel Facility Projects inspection (Inspection Report No. 70-1201/92-02).

No violations or deviations were identified.

3. Safety Review Board (88005, 88015, 88020)

Section 2.3 of the license app _lication establishes the CNFP Safety Review Board (SRB) and specific requirements associated therewith. The membership of the SRB and their responsibilities are specified in _.

Procedure AS-Il20, "CNFP Safety Review Board," Revision (Rev.) 4,-dated March 5, 1991. The inspector reviewed the minutes of the SRB for meetings dated February 21, 1992, May 28, 1992, September: 3, .1992, and -

November 12,.1992, and determined that the meetings had been held at the-required frequency with the required membership present. lhe inspector also determined that the agenda for items reviewed were in accordance-with the charter. The inspector had several questions inquiring about-background details on many of the items discussed in the meeting minutes,-

all of which were answered satisfactorily. The meeting minutes were informative and otherwise indicative of the SRBs function fully meeting

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the intent-of the license condition.

No violations-or deviations were identified.

4. Training (88010)

Section 2.5 of-the license application establishes the'CNFP radiation worker training / retraining program and specific requirements associated therewith. The inspector determined that procedural controls were in place for employee safety training: Procedure No. AS-Il01, " Employee -

Safety Training, Rev. 14, dated June 12, 1992. Radiation. safety.

2 refresher training was last completed in December 1991, as indicated by records in the training file. During the week of this inspection, radiation worker training for 1992 was being conducted. The inspector-attended the NCS portion of one of the training sessions which eppeared adequate. -

No violations or deviations were identified.

5. Nuclear Criticality Safety Audits.(88005, 99015, 88020)

Section 2.7 of the license application establishes the CNFP internal audit program and specific requirements associated therewith. The-inspector reviewed the nuclear safety audit reports for the first and second halves of 1992. The audit reports were documented by letter Nos. JWH92-33 and JWH92-55, dated July 6, 1992 and November 16, 1992, respectively. The audit reports were indicative of thorough audits and no violations were identified. The audits were conducted in accordance with requirements of the license application and a written procedure:

AS-ll25, " Health-Safety Audits," Rev. 11, dated January 20, 1992.

No violations or deviations were identified.

6. 10 CFR 21 Reporting of Defects and Noncompliance (36100) 10 CFR 21 requires the reporting to the NRC of defects and noncompliance which could create a substantial safety hazard. The inspector discussed this requirement with a CNFP representative who indicated that their program had not identified any reportable items. Their program _is implemented by procedure No. AS-ll28, " Reporting of Defects and Noncompliance - 10 CFR'21," Rev. 8, dated January 22, 1988 and reaffirmed June 12, 1990.

No violations or deviations were identified.

7. Unusual incidents (Criticality Safety) (88005, 88015, 88020)

A CNFP representative stated that there had been two unusual incidents of a criticality safety nature since the last Fuel Facility Projects inspection (Inspection Report No. 70-1201/92-02). The first incident involved the accumulation of fuel particles.(from broken pellets) in a ventilation duct associated with a pellet loading table and is discussed in Inspection Report 70-1201/92-04. The second incident involved a roof leak in the pellet receiving / shipping area. Both of these incidents had been reported to management and CNFP had determined that neither of these incidents was reportable as per NRC Bulletin 91-01, " Reporting Loss of Criticality Safety Controls." The reporting and subsequent handling of these incidents was conducted in compliance with procedure No. RP-020,

" Reporting loss of Criticality Controls," Rev.1, dated May_7,1992. The inspector discussed these incidents with the CNFP representative, toured the operation and area involved, and their corrective actions appeared )

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3 adequate. The roof leak had been repaired and the duct was put onto-an inspection / cleaning schedule-in a maintenance procedure in addition to an observation port having been installed. -Inspector Followup Item (IFI) 92-04-03 is closed.

Regarding the roof leak, licensee documentation of. this incident and-related discussion with a CNFP representative indicated that, although.

operators had taken action to contain the water from the leak, they had not reported the leak to management. The leak was ultimately discovered by the Safety and Licensing Manager who reported it to higher management.

CNFP management had recognized the problem with the notification and had reinstructed operators accordingly. The area is not a moderation controlled area, so the presence of full moderation in the area is assumed by CNFP's NCS evaluation. However, the actual physical introduction of water is a safety concerns which CNFP management had recognized and addressed.

8. Criticality Monitoring System (88015, 88025)

Section 3.2.4.3 of the licensee application establishes the required functional testing and calibration frequency for the criticality monitoring system. The license requirements were implemented by procedure No. RP-018, " Calibration and Maintenance of the Criticality-Alarm System," Revision 0, dated July 15, 1991, which appeared to meet -

the criteria delineated in Section 6, " Testing," of American National Standard ANSI /ANS-8.3-1986, " Criticality Alarm System." The inspector reviewed the functional test and calibration records for 1992.

No violations or deviations were identified.

9. Preoperational Audits of Changes (88005, 88015, 88020)

The inspector reviewed a file of preoperational audit documentation- for-calendar year 1992 and noted-that none related to plant nuclear criticality safety.

No violations or deviations were identified.

10. Fuel Handling and Storage (88015, 88020)-

Chapter 4.0 of the license application establishes requirements for' fuel handling and storage. During tours of the production areas, the

- inspector observed the handling of pellets, fuel- rods and fuel assemblies. All observed-activities were in according with nosted safety-limits and storage-requirements. -Completed assemblies were stored in permanent fixtures. Storage and transport of fuel pellets were in accordance with the license requirements for-slab thickness, and unit

- separations.

No violations or deviations were identified.

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11. Followup on NRC Information Notices (92701)

Discussion with a CNFP representative indicated that they had evaluated the following NRC Information Notices (ins) and taken appropriate action if applicable:

IN 91-84 Problems with Criticality Alarm Components / Systems IN 92-14 Uranium 0xide Fires at Fuel Facilities No violations or deviations were identified.

12. Chemical Storage Building (88020)-

The inspector toured CNFP's new chemical storage building with a CNFP representative. The building appeared to be well designed and utilized with drums stored in an upright position to preclude leakage and a separate, diked area for acids to preclude the mixing of acids and organics in the event of a spill.

No violations or deviations were identified.

13. Implementation of New Fuel Handling Limits for Enrichment Up to 5.1 Percent (88005, 88015, 88020)

On October 21, 1992, ONMSS approved a license amendment application for handling fuel beyond CNFP's previous limit of 4.1 percent (%) Enrichment (E) and up to a new limit of 5.1% E. Accordingly, Section 4.2 of the license application is now revised to include new,-more restrictive fuel handling limits for fuel. where 4.1% < E s 5.1%. During the week of=this inspection, CNFP was not yet handling greater than 4.1% E fuel, and a -

CNFP representative stated that the new fuel handling limits would not be implemented until a fabrication contract for greater than 4.1%-E fuel was started. The CNFP representative stated that at that time; however, all fuel would henceforth be handled as if it were 5.1% E, except in -fuel assembly storage where different racks with different spacing would be used for the two enrichment ranges, E s 4.1% and 4.1% < E s 5.1%.

Discussion of the tentatively planned implementation methods-for the new limits indicated that they would appear to be adequate. Planned implementation for pellets consists of the 25-inch slab width and 12-inch; separation between slabs being maintained by passive engineering i controls. Fuel rod limits did not change with the enrichment increase '

and fuel assembly storage is addressed above.

I l No violations or deviations were identified.

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14. Exit Interview The inspection scope and results were summarized on December 11,'1992,-

with those persons indicated in Section 1. The _ inspector described in detail.the inspection-results. Although reviewed during this. inspection, -

proprietary information is not contained in this report. Dissenting-comments were not received from the licensee.

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