ML20133D029

Insp Rept 70-1257/96-206 on 961202-05.Violations Noted. Major Areas Inspected:Fuel Fabrication Facility in Richland,Wa,Activities Associated W/Planned Startup of New Dry Conversion Facility & Review of Hq Insp Procedure 88015

ML20133D029
Person / Time
Site:	Framatome ANP Richland
Issue date:	01/03/1997
From:	Ting P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20133D015	List: ML20133D012 ML20133D023 ML20133D029
References
70-1257-96-206, NUDOCS 9701080172
Download: ML20133D029 (12)

Text

_ _ . _ _ . . . _ _ _ _ . . . _ - _ . _ _ . _ _ . .__ _ - . _ _ _ _ .-_ .

l

\

! U.S. NUCLEAR REGULATORY COMMISSION l OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS l Docket No. 70-1257 License No. SNM-1227 Report No. 70-1257/96-206 Licensee: Siemens Power Corporation Location: 2101 Horn Rapids Road Richland, WA 99352-0130 Dates: December 2 - 5,1996 Inspectors: William Troskoski, inspector, NRC Headquarters Dennis Morey, Inspector, NRC Headquarters Sunder Bhatia, Inspector, NRC Headquarters l

l Santiago Parra, Regulatory Engineer, NRC Headquarters l

Douglas A. Outlaw, Consultant '

I -

Approved gl l

j By: Philip Ting, Chie Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS l

l l

l Enclosure 2 f

i 9701080172 970103 PDR ADOCK 07001257 C PDR -

_ ,. .. ; --3r

4 l

\

1 EXECUTIVE

SUMMARY

l SIEMENS POWER CORPORATION l NRC INSPECTION REPORT l 70-1257/ % -206 Areas insoccted NRC performed a routine, unannounced criticality safety inspection of the Siemens Power Corporation (SPC) fuel fabrication facility in Richland, WA on l December 2 - 5,1996. The inspection was conducted using staff from NRC j Headquarters and a contractor. The focus of this inspection was on the activities associated with the planned startup of the new dry conversion facility (DCF) and a review of HQ inspection Procedure 88015 requirements, which were not completed during the previous inspection.

Major programmatic portions of the nuclear criticality safety (NCS) program which were reviewed at SPC included:

4 e Nuclear Criticality Safety Function e Plant Activities e Configuration Control for Nuclear Criticality Safety e Nuclear Criticality Safety Change Control e Nuclear Criticality Safety Training e Nuclear Criticality Safety inspections, Audits, and Investigations Results e The qualifications of personnel and staffing levels met the license requirements and were adequate for current responsibilities.

e The process by which criticality safety limits and controls identified in Criticality Safety Analyses (CSAs) were implemented in the plant was generally adequate. Ilowever, the inspectors identified one instance in which the mass controls specified in a Criticality Safety Limit Card had been changed but the revised card had not been posted in the workplace.

This failure occurred because several administrative controls were not properly implemented (Detail 3.0).

.1 a. u }ny ~

e The document control system at the plant appeared effective in ensuring that " controlled" documentation was maintained in the " mini-libraries" located throughout the plant. Isolated problems were discovered in updating of other documentation, such the criticality safety standards and the criticality safety limit cards (Detail 4.0),

e The overall level of safety-related housekeeping was generally adequate.

Ilowever, several examples of unlabeled, nominally empty SNM containers were found, housekeeping and maintenance of safety showers needed improvement, and public address and intercom loudspeakers had material packed into them to reduce the volume (Detail 3.0),

o The Engineering Change Notice (ECN) process, in conjunction with the use of a Startup Council, provides adequate management control over the startup activities for the new Dry Conversion Facility (Detail 5.0).

e Appropriate lessons learned reviews of industry events for applicability at SPC were conducted in a timely manner (Detail 5.0).

• The criticality safety violation, identification, tracking and resolution system was adequate and trend analysis and corrective action were also satisfactory (Detail 7.0).

e The training program was effective in ensuring that operations personnel understood and properly implemented criticality safety controls (Detail 6.0).

DETAIIE 2.0 Nuclear Criticality Safety Function

a. Scope The inspectors reviewed the qualifications and staffing levels for the NCS function to verify that adequate, qualified staff are available to perform the responsibilities in Part 1 of the license application.

b. Observations Since the last NRC HQ inspection, one qualified SPC criticality safety specialist resigned to pursue other interests. This left the NCS function ,

u -- , 49.[. - a i?1m

1<

1 .

l i with only two qualified criticality safety specialists to perform the required

functions that had previously been performed by three, including ,

preparation of analyses, second-party reviews, audits, and support to f i

operations. A third SPC nuclear engineer had recently been added to the j criticality safety group and is undergoing qualification training. The two-engineer staffing level observed performing criticality safety functions was clearly below the level desired by SPC. t

' ^

i In spite of staffing limitations, no problems were observed with the overall

} quality of the criticality safety assessments (CSAs) and the independent '

l reviews. Isolated problems were identified with the implementation of criticality safety limit cards (see Section 3.0). In the longer term, the j addition of a third engineer to the group should help relieve the workload j on the two qualified criticality safety specialists.

)

l At current staffing levels, the inspectors were concerned that the NCS 2 function would not be able to fully support the startup schedule for the

new DCF and maintain their existing responsibilities for the safe operation t of the remainder of the plant. Plant management indicated that they )

{ intended to continue to meet the applicable license requirements while  ;

j pursuing a responsible schedule for completion of the DCF project. '

i l

i c. Conclusions J 1 l

The inspectors found that although the staffing levels were low, the

qualifications of personnel and staffing levels were adequate to perform the

) responsibilities identified in Part I, Chapter 2 of the license application for current operations.

J 4

3.0 Plant Activities

! a. Scope i

The inspectors reviewed the process by which criticality safety limits and i controls identified in selected CSAs are implemented in the plant.

i Transmission of CSA identified limits and controls were traced through the

!' Criticality Safety Specifications (CSSs) and Criticality Safety Limit Cards and into the workplace for operator use. Plant tours were conducted to j verify that selected safety related controls were properly implemented.

l 1 i l

._ L _n

b. Observations The licensee's nuclear criticality safety evaluations for each plant area or operation are documented in specific CSAs. The first section of a CSA identifies the criticality safety controls and other relevant safety information. The NCS staff transmits this information to the operations department through a CSS. The CSS preparation process only required a

" cut-and-paste" of the identified limits and controls from the CSA to the CSS. In all of the cases reviewed by the inspectors, the limits and controls identified in the CSAs were correctly identified in the CSSs.

Criticality Safety Limit Cards are posted in the workplace as an operator aid. Each posted card can contain selected requirements from one or more CSSs. The process by which information is extracted from multiple CSSs for inclusion on the posting was found to lack formality (see Detail 4.0 for further discussion).

The inspectors reviewed selected operating areas to verify that the correct Criticality Safety Limit Cards were posted for operator use.

Except for the UF. Cylinder Wash Station (P90,034), a current limit card was found to be posted for each area. Subsequent discussions with licensee personnel indicated that the controls for this station had been changed, and Revision 2 to the limit card had been issued on April 17, 1996. Although the revised limit card had J been placed in the " mini-libraries" throughout the plant by ,

document control personnel, the single card posted for operator use l at the cylinder wash station had not been updated to reflect the  !

revised controls. SPC management responded by immediately replacing the out-of-date limit card.

Although the latest controls were not in place at the UF. Cylinder Wash i Station, the ongoing operations were observed to be well within the mass  !

controls identified for both Revision 1 and Revision 2 of the limit card, i The principal control change between the revisions invoNed the replacement of the " safe batch limit tables" in Revision i to a single limit of "one 30 inch UF cylinder containing < 15 kgs UF ."

The CSA for the UF. Cylinder Wash Operation (CSA No. UO65, Rev. O, October 25,1996), and corresponding CSS Glo. P97,065, November 5, 1996) had been revised and issued by the NCS function and accepted by Plant Operations, since the limit card was issued on April 17,1996. The revision of these documents required inspections by both the primary i

l preparer, a second-party criticality safety reviewer, and the operations l staff. Each of these inspections should have discovered that the posting I did not correspond to the limits and controls clearly identified in the CSA )

and CSS.

4 Section 4.1.4.1, Criticality Safety Specifications, requires that Criticality Safety Limit Cards contain a concise statement of CSS to CSA limits applicable to an operation or area. The failure to post the updated Criticality Safety Limit Card for the UF 6Cylinder Wash Operation after it was revised is Violation 96 206-01. Enforcement discretion is not being applied to this case because multiple administrative checks involving independent organizational elements failed to identify the posting error. ]

l Over the course of the week, the inspectors toured a number of .

l plant facilities and found the overall level of plant housekeeping  !

and maintenance generally adequate, in several locations, I nominally empty SNM containers were observed to be stored in a j manner that did not clearly indicate that they were empty. The -

NCS engineer indicated that they were supposed to be labeled as 1

" empty" or be stored in an array with a sign indicating empty container storage. The licensee indicated that this condition would

{

be promptly addressed.

l During the plant tours, the inspectors noted that equipment and/or trash from a maintenance activity was being stored under a safety shower in the Solid Waste Uranium Recovery Area. Also, several green location lights above two safety showers were not functioning. SPC management indicated that the safety shower conditions would be promptly addressed. l The inspectors observed speakers for the building intercom system in the control room and rod loading areas with material packed  ;

inside. Discussions with SPC staff indicated that the plant public j address system was used to broadcast criticality alarms in some ,

plant areas including the rod loading room. No visual indication was available in this area, and the inspectors were concerned about l reducing the volume of the loudspeakers to less than the required 10 dB above. ambient noise level. SPC management stated that they would evaluate and correct the situation immediately. This is Inspector Follow-up Item 96 206-02.

c. Conclusions Management controls, which insure that criticality safety limits and controls identified in CSAs are implemented in the plant, need improvement. Additional management attention is required to assure that the responsible organizational units adequately verify that revised Criticality Safety Limit Cards are posted.

The overall level of safety-related housekeeping was found to be generally adequate. Additional attention toward labeling of empty SNM containers, maintenance of safety showers, and control of loudspeakers in the plant is warranted.

4.0 Configuration Control Program for Nuclear Criticality Safety

a. Smp_o Aspects of the configuration control program were reviewed to verify that recent changes to criticality safety documentation had been implemented at appropriate locations throughout the plant.

b. Observations The inspectors discussed changes to the plant since the last inspection and reviewed selected criticality safety documents associated with those changes. Portions of the plant were then inspected to verify that the appropriate changes had been made to support facility operations.

The plant has " mini-libraries" scattered throughout the plant that contain the controlled documents as well as other documents needed by plant staff.

The " controlled" documents are maintained in these mini-libraries by the document control group. Random checks at several locations indicated that the latest revision to several CSSs and Criticality Safety Limit Cards, which are " controlled" documents, were in these mini-libraries.

The inspectors found one mini-library that did not have the current revision of " Chapter 3, Nuclear Criticality Safety Standards" in the copy of the "Siemens Power Corporation Safety Manual." The manual at that location had Revision 23 dated July 1995, and the criticality safety staff indicated that the latest version was Revision 27 dated August 23,1996.

The SPC NCS engineer indicated that the responsibility for updating the

, _ .u

l I

l .

8 l

manual at this mini-library was the individual manual owner and not the document control group. SPC management indicated that the manual would be immediately updated.

Several cases were identified in which the posted Criticality Safety Limit l Cards referenced a CSS that was not the current CSS listed in EMF-38,

" Criticality Safety Specifications and Limits." In some cases, the CSS document number referenced on the limit card was no longer on the list in EMF-38. Discussions with SPC NCS staff indicated that the referenced CSSs were earlier documents that had subsequently been revised and, in some cases, a new document number issued. The staff also indicated that there was a reluctance to change posted limit cards if the changes were not deemed substantive. Part I, Chapter 4, Section 4.1.4.5 of the license application requires that "The limit card has a title and number such that the card is traceable to the CSA that supports it." Tla SPC NCS staff were able to quickly indicate the correct CSS and CSA reference for the limit cards questioned through the limit card title and number. 1

c. Conclusions The document control system at the plant needs improvement. Additional attention is required to assure that documents such as criticality safety I standards and criticality safety limit cards are promptly updated. l l

l 5.0 Nuclear Criticality Safety Chance Control l

a. Scope The change control process was reviewed to ensure that changes {

potentially affecting NCS are identified, reviewed, and evaluated m  ;

accordance with license commitments,

b. Observations l Dry Conversion Facility (DCF) l The inspectors discussed the planned approach for implementation of criticality controls to the startup of the dry conversion facility now under

, construction. Senior SPC managers indicated that the new building and process were being managed in accordance with the ECN procedure.

They indicated that the ECN process was well established and understocxl

at SPC and would be used for the entire DCF project. Several ECNs were being used or planned for the specific phases of the project. Initial ECNs were used for preparation of the foundation and construction of the building shell.

Since the ECN process was primarily developed for smaller, discrete packages and not large projects, SPC implemented a Startup Council for review and approval of specific steps and actions. Multiple design reviews were expected prior to commencement of operations in the DCF.

i' Discussions with NCS and management staff indicated that five criticality safety analyses are planned for the DCF, but had not yet been completed. l Since the planned equipment is quite similar to that in the DCF pilot j operations (one of the currently licensed operating lines is using this '

technology), the criticality control strategies were expected to be similar.  :

The SPC staff at Richland had also prepared the CSAs for the SPC dry l conversion facility constructed at a foreign site and expect the CSAs for l the new DCF to be similar. The staff indicated that the normal ECN process should be adequate to ensure that the CSAs and CSSs would be

)

adequately reviewed, approved, and implemented.

Solid Waste Uranium Recovery (SWUR)

Changes to the criticality safety controls for the SWUR since the last HQ criticality safety inspection were reviewed to verify that selected controls had been implemented. Since the commencement of SWUR operation under moderation control for the lower incinerator chamber, higher than expected moisture levels were found in the incinerator ash. Pending identification of the cause(s) for the unexpectedly high moisture levels, the licensee has modified the system criticality safety control strategy by placing additional mass controls over the operations. Review of the revised CSAs, CSSs, and limit cards and inspection of the facility indicated that these controls had been successfully implemented.

The Inspectors also reviewed changes to the SWUR process in response to lessons learned from the 1996 Nuclear Fuel Services (NFS) incinerator fire. As a result of the licenze's internal review, several changes were made to the operating procedures. During a tour of the SWUR, the inspectors noted that a copy of the revised procedures had not been placed in the local procedure book. Discussions with the process engineer indicated that he was aware of this situation and that further procedure 1

revisions had occurred. The inspectors were informed that the SWUR operation had been shut down prior to the procedure revisions. In addition, final updated procedures were scheduled to be put in place and all of the operators retrained on the procedure revisions prior to restart of the SWUR station.

c. Conclusions The proceduralized ECN process, in conjunction with the use of a Startup Council, appears to provide adequate management control over the startup ,

of the new Dry Conversion Facility.

The changes made to the criticality safe:y controls for the SWUR process in response to the NFS incinerator fire and the discovery of higher than expected levels of moisture in the incinerator ash were adequately controlled.

6.0 Nuclear Criticality Safety Training

a. Scope ,

1 The inspectors observed selected operations and interviewul operations staff to verify that personnel were aware of the criticality safety controls, were adequately trained, and were following procedures.

b. Observations The Inspectors observed operations at the Powder Packaging workstation and interviewed operations staff to verify that the staff were aware of the criticality safety controls, had been adequately trained, and were following the operating procedures. In all cases, the operators appeared well qualified and performed their jobs in accordance with the approved procedures. When questioned on their response to various abnormal I conditions, they all responded adequat::ly. No concerns were identified.  !

c. Conclusions The inspectors found that the operators appeared well trained and understood and followed the criticality safety controls applicable to their l assignment. No additional concerns or issues were identified.

._-. _ - . . _ . . - _- -.- - - - . _ - _ - . . . - . - . - - - . - . - . ~ - -

i i ,

l

)I j 7.0 Nuclear Criticality Safety insoections. Audits. and Investigations

! a. Scope i.

l The Inspectors reviewed documentation and interviewed management actionees to verify that criticality safety violations l

were identified, reported, reviewed, and tracked to completion.

b. . Observations Three SPC identified criticality safety violations were selected by the inspectors for review. The violations involved the breakdown

! of an auger in the #3 blender, an unattended and improperly stored l uranium powder contaivrf and a uranium powder container with l 14 kg of powder and no label. Inspectors interviewed SPC j management perronnel responsible for closure of the associated ,

j corrective actiors. All of the actionees maintained files of j -

criticality safety violations and were aware of their respective

corrective action assignments. Completed corrective actions were reviewed by the inspectors both in-plant and with the assigned licensee personnel to verify adequate closure. In all cases

! reviewed, adequate currective action had been taken and

documen

cd. .

l SPC management reported that there had recently been an increase 1 in the number of criticality safety violations possibly due to recent i reductions in the work force and resulting changes in the workload

of operations staff. SPC NCS staff analyzed this trend and held meetings with operations staff to identify problems. Corrective ,

actions for problems identified during this process have been developed and were being implemented.

c. Conclusions The criticality safety tracking system was adequate, actionces were aware of their respective responsibilities, and closure of action items was documented. Trending of minor liCS infractions was conducted and reviewed by senior plant enanagement. Corrective actions were identified and assigned, and were adequately resolved.

l

,. =p '

4 MANAGEAfENT MEETINGS Exit Meetine Summary The inspectors met with SPC management throughout the inspection. An exit meeting was held on December 5,1996. No proprietary information was identified. The following is a partial list of exit meeting attendees:

l Siemens Power Corooration 1

Ray Vaughan, Safety and Security Manager l Tom Probasco, Safety Manager Cal Manning, Criticality Engineer Loren Maas, Regulatory Compliance Manager 1 Jim Edgar, Licensing Manager Nuclear Regulatory Commission William Troskoski, Inspector, NRC Headquarters Dennis Morey, inspector, NRC Headquarters Sunder Bhatia, Inspector, NRC Headquarters Santiago Parra, Regulatory Engineer, NRC Headquarters Douglas A. Outlaw, Consultant

)

j LIST OF ACRONYMS USED 3

1 l

j CSS Criticality Safety Specification  ;

CSA Criticality Safety Analysis l

~ PDR Public Document Room l DCF Dry Conversion Facility l l NCS Nuclear Criticality Safety ECN Engineering Change Notice

] SWUR Solid Waste Uranium Recovery

, NFS Nuclear Fuel Services l'

I l,

l j

t.

, . , - , . - - .,.