ML20137T547

Insp Rept 70-1113/97-02 on 970303-07 & 17-21.No Violations Noted.Major Areas Inspected:Operations,Training,Construction Completion & Training & Functional Testing of Sys

ML20137T547
Person / Time
Site:	07001113
Issue date:	04/08/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20137T539	List: ML20137T535 ML20137T547
References
70-1113-97-02, 70-1113-97-2, NUDOCS 9704160120
Download: ML20137T547 (19)

Text

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U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.:

70-1113 l

License No.:

SNM 1097 Report No.:

70 1113/97-02 Licensee:

General Electric Company Facility:

Nuclear Energy Production Location:

Wilmington, North Carolina i

Dates:

March 3 7, 1997 March 17-21, 1997 Inspector:

G. L. Troup Sr. Fuel Facilities Inspector Approved by:

E. J. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety Enclosure 9704160120 970408 PDR ADOCK 07001113 C

PDR

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1.

EXECUTIVE

SUMMARY

General Electric Nuclear Energy Production i

NRC Inspection Report 70 1113/97 02 i

j This routine, announced inspection was focused on the status of the new Dry i

Conversion Facility (DCF), including operations, training, completion of i

,i construction, training and functional testing of systems. Review of 2

previously identified items and reported occurrences was also conducted. Back shift inspections were conducted on March 17, 18, 19, and 20. The inspection was focused on the safe operation of the facility.

i Within the scope of the inspection, no violations or new inspector follow up l

4 items (IFIs) were identified.

l Plant Operations i

The long term corrective actions for calciners were completed. The l

e corrective actions for No. 6 calciner were also completed.

i The actions to identify and control an improperly identified shipment of l

e radioactive material from a foreign shipper was thorough and timely.

I e

The actions to identify and quarantine possibly defective valves for UF i

6 cylinders was thorough and timely.

i i

Trainino

]

1 The training program for the operators in the Dry Conversion Facility e

has been completed and the pre qualification phase has started.

l e

Special training on hydrofluoric acid accidents, including emergency personnel and off site support groups, is a positive action.

)

Dry Conversion Facility Construction e

Construction of process line 1 and the acid recovery facility is complete.

Pre-operational testing has begun.

j e

The adequacy of criticality warning system and the stationary air i

samplers has not been demonstrated.

Process Safety Analysis The safety analysis was a thorough in-depth evaluation of potential e

hazards and safeguards against the hazards.

Attachments Partial List of Persons Contacted Inspection Procedures Used List of Itees Opened, Closed and Discussed List of Acronyms t

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T i

REPORT DETAILS l

Summary of Plant Status 1

This report covers two one week periods.

On March 11, the FM0/FM0X building was evacuated when the Criticality Warning System (CWS) alarmed, although it was a false alarm (Paragraph 1.d).

Construction and testing activities for the Dry Conversion Facility (DCF) were progressing.

l The State of North Ccrolina materials license 065 017 1 was renewed on Mar.3 3, 1997. This renewal permits operation of the DCF with natural i

uranium.

An NRC Material Control and Accountability (MC&A) inspection was conducted on March 3 7, 1997 (report 70 1113/97-201). Additionally, the license reviewer for chemical safety was on site on March 18 19. 1997, as part of the license renewal review for license SNM 1097.

1.

Review of Previous Events (88020) a.

Calciner Tube Failure l

(1)

Inspection Scope The inspector reviewed the licensee's corrective actions resulting from the failure of the tube in the Line 3 calciner.

(2)

Observations and Findings l

The Line 3 calciner tube failure reported to NRC on December 3, 1996, and reviewed in NRC Inspection Report (IR) j 70 1113/96-12, prompted the licensee to consider L number of long and short-term corrective actions to preclude a similar event. These corrective actions were documented by letter to Director, Division of Nuclear Materials Safety, Region II, dated December 11, 1996. Attachment III of the letter lists nine corrective actions, the first five of which were to be completed prior to restarting each calciner which processes wet material.

Implementation of the corrective actions was reviewed and documented in NRC IR 70 1113/97 01.

At that time, three of the corrective actions had not been completed. During this inspection, the inspector reviewed the completion of these items and the completion of all items for No. 6 calciner.

Correci.ive action #6 was to be implemented by explicitly modeling material accumulations within the calciner annulus beyond the 25 kilogram (kgs) hemisphere previously analyzed.

The analysis (file no. CR #97.NRC) was completed and

2 reviewed on March 19, 1997. The results of the analysis l

show that with the tube y full of optimally moderated UO2 powder at 5% enrichment and material accumulated in the annulus up to 5.25 inches the entire length of the calciner, k, remains less than 0.97. The total mass of powder for tusconfigurationis1,145kgs.

for the system, of which j

736 kgs, are in the annulus. The previous actions to monitor the tube rotation and the off gas should identify upset conditions before this limit is reached.

Corrective action #7 was to revise the purchase specification for replacement tubes to require a final stress relief after welding. During the review in January, 1997, it was not anticipated that any new tubes would be ordered in the near future.

However, the calciner tube is carried in the licensee's spare parts computer inventory. When the replacement tube was drawn from spare parts for installation in No. 3 l

calciner, the computer system initiated purchase of a new 1

one since the inventory was now depleted. A purchase order i

was initiated in December, 1996. The price quotation was received from the vendor on January 17, 1997. At the time, licensee representatives recognized that the specification had not been revised before the request for quotation had been sent out. On January 22, 1997, the vendor was advised by telephone that annealing after welding was required: this 1

was confirmed by a FAX the same day. A revised quotation was received from the vendor on February 5,1997, which i

stated that the tube would be annealed after welding, i

The inspector questioned whether the corrective action had been completed, as stated in the licensee's letter of February 25. : 97, in response to the Notice of Violation in j

IR 70 1113/96 12. After discussions, it was determined that the purchase was not complete until the quotation was l

confirmed by a purchase order, and the requirements had been changed in January, so the specification had been changed before the next tube was " ordered." However, licensee re)resentatives acknowledged that the specifications for the tu>e in Stores File should be revised so that they would be correct if it became necessary to order another tube.

On March 5,1997, drawing 0166D91 " Alloy Defluorinator Tube,"

was revised (Revision 3) to include " NOTE: General Electric requires annealing after roll tube final welds are completed. " The Stores File was revised on March 6, 1997, to include Revision 3 of the drawing and the requirement that " tube must be annealed after completion of welding" was added to the specification.

t i

3 Corrective action M was to revise the change control system l

to require review of any impacts of material changes in process equipment. On February 11, 1997, a mandatory 1

modification was issued to Practices and Procedures (P/P) 1010. " Configuration Management Program Fuel Manufacturing," which requires that the Area Engineer is i

responsible to " evaluate the impact of materials property j

changes on identified failure modes and safety basis." This completed Corrective Action M.

No. 6 calciner was not modified when the others were because 4

it was out of service and only processed dry material (recycled powder). No. 6 calciner was brought up to standard by modifying the control system to automatically close the rotary airlock valve from the feed hopper if the tube rotation switch timed out. The control system was also i

modified to shut the rotary airlock valve if the necessary 4

air sample data is not entered at the required frequency.

Software Service Request (SSR) 13937 was implemented for

'i these control changes and approved by the software engineer on February 13, 1997, and accepted by the system " owner" on February 14, 1997. Functional Test Instructions (FTIs) 3C8DF8 and 3C8DF4 were performed on February 13. 1997, to 4

verify that the system functioned.

No. 6 calciner was approved to operate by the Area Engineer, Area Manager and Manager, Nuclear Safety on February 13, 1997. The inspector reviewed the FTI results, the check lists for the modification, the SSR, the revised technical report and operating procedure and had no further questions.

(3)

Conclusions The modification to No. 6 calciner was completed in i

accordance with the licensee's commitments and internal i

procedures, b.

Imoroper Material Shire:ent (1)

Inspection Scope l

The inspector reviewed the circumstances involving the receipt of improperly labeled material from a foreign shipper.

i (2)

Observations and Findings 5

On March 7, 1997, while unloading a seavan shipping i

container which contained 150 Model BU J shipping containers, licensee employees observed that two of the BU-Js had tampersafe seals attached to the bolting ring. These containers were supposedly empty and did not require l

tampersafe seals.

The employees notified the cognizant d

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1 personnel.

The BU J containers were moved to a work area 2

i and opened. Both BU Js were found to have two 5 gallon cans inside which were labeled with the content weight. Surveys i

indicated that the contents were radioactive. A visual 3

examination of the remaining BU Js did not identify any more which had tampersafe seals but subsequent radiation surveys i

identified an additional BU-J which contained radioactive material. This container was moved to the work area and i

confirmed to have two 5 gallon cans inside containing l

material.

I The licensee notified the shipper, Empresa Nacional del Uranio, SA (ENUSA), a Spanish company, when the two BU-Js were found with the tam>ersafe seals. ENUSA reviewed their records and confirmed t1at the two containers contained i

uranium material. The ENUSA records search also identified the third container.

From the ENUSA ecords, a total of i

102.41 kgs. of uranium oxide with a maximum enrichment of l

4.4% had been ship >ed.

Following notification of the improper shipment ay the licensee, ENUSA notified the Consejo de Seguridad Nuclear, the Ministerio de Industria y

}

Energia and EURATOM of the improper shipment. The licensee i

notified the NRC, the Department of Transportation and the State of North Carolina.

2 The licensee installed tampersafe seals on the three BU Js j

and placed them in temporary storage. An Unusual Incident Report (UIR) DCP-9701 was generated and corrective actions J

identified.

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I At the conclusion of the inspection, the investigation report from ENUSA had not been received.

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j (3)

Conclusions The actions of the licensee employees to identify an unusual 4

condition was exemplary.

4-The licensees actions to quarantine the shipment and to l

conduct surveys to identify any additional containers was thorough and timely.

c.

UF Cylinder Valves s

(1)

Inspection Scope The inspector reviewed the licensee's action after being notified of a materials problem with valves which might be installed on UF cylinders at the facility.

3

5 (2)

Observations and Findings On March 14, 1997, the U. S. Enrichment Corporation (USEC) gaseous diffusion plant at Paducah, Kentucky notified the NRC Operations Office of a stress corrosion cracking problem with the packing nut on Hunt Valve Co. valves (NRC event number EN 31954).

In particular, Hunt Valve Co. valves with the Jacking nut made of Alloy 636 had experienced cracking of t1e nut, had failed and, in one case, resulted in the release of UF.

6 On Harm 21, 1997, NRC Region II notified facilities in the region of the

]roblem and requested that the licensees determine if t1ey had any of the valves in question.

The licensee's initial action was to check all valves in the spare parts inventory (55) and the cylinders on the loading dock (about 30). All Hunt Valve Co. valves had nuts of Alloy 613 although some valves manufactured by Superior or Descote had Alloy 636 nuts.

The licensee contacted both USEC Paducah and Hunt Valve Co.

and determined that the problem appeared to be limited to Hunt valves. Also, Hunt Valve Co. stated that they had switched to Alloy 613 nuts in about 1991.

During t.ie week of March 17, the licensee inspected the valves on all UF, cylinders on site (approximately 275) and found nine Hunt valves with nuts of Alloy 636.

Eight were empty and will be returned to the owner for replacement of the valves.

One full cylinder was subsequently placed in the cold trap and the valve replaced before it was sent to a l

vaporizer for processing.

USEC Paducah stated that they would not fill any cylinders with Hunt valves with Alloy 636 nuts.

However, Hunt Valve Co. estimates that there could be u) to 5,000 valves in circulation with Alloy 636 nuts.

T1e licensee issued 0 Temporary Operating Instruction (TOI) to inspect all incoming cylinders for the Hunt valves with Alloy 636 nuts because UF cylinders come from sources other than USEC Paducah.

theTOIwillbeevaluatedafterseveralmonthsto determine if continued action is necessary.

(3)

Conclusions i

The licensee took thorough and effective actions to identify the scope of the problem and to take corrective actions to preclude the processing of cylinders with suspect valves.

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d.

Criticality Warnino System l

(1)

Inspection Scope The inspector reviewed the cause and corrective actions 2

taken after a false signal from the criticality warning system (CWS) in the Dry Conversion Facility (DCF) caused the evacuation of the fuel manufacturing facility on March 11.

L (2)

Observations and Findings j

On March 11, 1997, a technician was trouble shooting a aroblem with the Data Acquisition Module (DAM) on the CWS in XF. He placed the control switch in " maintenance" to turn i

off the >ower, then pulled the suspect Input / Output (I/0) board.

) lacing the switch in " maintenance" should have deactivated the DAM and given a signal in the Radiation l

Protection office and in the Emergency Control Center (ECC).

However, when the I/O board was pulled, the CWS for the Fuel Manufacturing Operation activated and sounded the plant i

evacuation alarm. All fuel operations were properly evacuated and the ECC was manned until the problem could be evaluated.

Radiation surveys and review of the CWS detector i

read outs revealed that the alarm was false and no l

criticality had occurred.

The licensee's investigation and discussions with the vendor determined that the DAMS which had been provided included a t

i reduadant fail safe relay in the circuit. The licensee had requested that the vendor install the switch with

• maintenance" mode. However, the switch did not override i

the relay. The sub contractor who ordered the DAMS a)parently was not aware of the effect of the relay. With t1e switch in " maintenance", detectors could be replaced but any maintenance on the DAM required that the system be shut down because of the relay. However, the licensee expected that the DAMS would activate on a true signal or upon a

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failure, 1

After discussions with the vendor, vendor representatives were on site on March 18, 1997, and removed the relay l

circuit from the DAMS.

Now, the licensee can work on the 2

boards using the " maintenance" mode on the switch.

(3)

Conclusions No defect was pcasent in the equipment received, s

The licensee's investigation as to the cause of the alarm was thorough and adequately resolved the problem.

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2.

Trainina (88010) l a.

Operator Trainina (1)

Inspection Scope The inspector reviewed the training and qualification program to qualify supervisors, operators and technical support personnel for the Dry Conversion Facility (DCF).

(2)

Observations and Findings The DCF represents a new process technology. Selected members of the staff were sent to the supplier's facility in France for initial training.

Operators and maintenance personnel assigned to the operating shifts attended a training program consisting of approximately 450 hours0.00521 days <br />0.125 hours <br />7.440476e-4 weeks <br />1.71225e-4 months <br /> of classroom instruction.

This formal training was completed on March 14, 1997. This training consisted of four general groups:

lay out, controls, general and supplemental.

Lay out training was concerned with the facility and system arrangement.

Controls training concerned the various controls associated with the operations and how the process operates.

General training was training on a variety of topics including the metric system, instrumentation, the Integrated Safety Analysis, Piping and Instrumentation Diagrams (P& ids) as well as a variety of subjects such as material control and accountability, radiation safety, nelear criticality safety, and industrial safety.

Supplemental training was additional training on specific topics, including additional training on chemical safety.

Each of the sessions was followed with a learning evaluation. The evaluation was similar to a written examination which was used to assess the learner's understanding of the subject material. The evaluations were used to determine subject areas which required additional individual instruction.

Once the classroom training was completed and shift coverage began, the operators started work on the completion of qualification cards for eleven different stages.

Because no uranium or utility service were in use during 3 art of this stage, qualificction was only "simuiated" at t11s stage.

When the classroom and simulated qualifications (in addition to additional supplemental training) were completed, the pre qualification summary is signed by the Operations

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Resource (OR) and the Area Manager.

(The OR acts as a ccordinator for the shift team and performs many of the 8

functions associated with the Area Coordinators (ACs) in other plant areas.)

Specialized training was also provided for instrument technicians (8 weeks) and maintenance personnel (2 weeks).

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(3)

Conclusions The training program was a major effort which addressed the various safety and operations topics.

j Completion of the training and pre cualification program appears to provide the basic knowlecge for the safe e

operation of facility.

j b.

Soecialized Trainina 1

(1)

Inspection Scope The inspector reviewed the special training conducted in association with the start up and operation of the DCF.

(2)

Observations and Findings The DCF uses hydrogen gas and nitrogen gas and produces hydrogen fluoride, which is converted to concentrated hydrofluoric acid (HF). Specialized training was conducted for the safety of these materials.

The licensee contracted with outside experts to conduct specialized chemical safety training. On March 3, specialized training was conducted on safety for hydrogen gas and nitrogen gas. This training was also given to members of the Emergency Response Team (ERT) and the Emergency Medical Team (EMT). On March 4 training, including practical exercises, was provided to the operators. EMT. ERT and other selected site personnel on HF.

In addition, members of the regional North Carolina Hazardous Materials (HazMat) team attended the training.

Specialized training on treating injuries associated with HF will be conducted for the local hospital personnel. This training is scheduled for early April.

(3)

Conclusions Specialized training in new chemicals associated with the DCF is a strong action by the licensee.

9 The inclusion of emergency ressonse (EMT, ERT) personnel and off-site personnel (state and lospital personnel) is a positive action by the licensee.

3.

Dry Conversion Facility Construction (88020) a.

Roof Construction (1)

Inspection Scope The inspector reviewed the status of the completion of the roof membrane and the installation of the leak detection system.

(2)

Observations and Findings The facility is designed as a " moderation exclusion" area where no moderating materials will be permitted, except under specifically designated conditions, in those areas where UO powder is produced or handled. A principal 2

feature of the " moderator exclusion" principle is the construction of a roof which precludes any leaks of rain into the facility.

Details of the roof construction are described in JCC drawings in the A21-ARXX series of drawings and the roofing material supplier project description. The DCF roof is designed to provide multiple Darriers to any leakage or seepage of external moisture into the DCF.

Details of the roof design and construction are discussed in IR 70-1113/96 02, Paragraph 4.

The inspector observed the installation of the roof edge seal and trim.

The installation of the seal and trim appeared to be in accordance with the project drawings and detailed sketches provided by the contractor.

As part of the roof construction, a leak detection system is installed to indicate leakage through the first membrane and the uaper slab.

The ins >ector observed that the drain pi>es l

have >een installed in t1ree locations on the drain troug1.

However, the drain collection columns have not yet been installed.

(3)

Conclusions The roof upper membrane and edge trim were installed in accordance with the project drawings.

l 10 b.

Process System Installation (1)

Inspection Scope The inspector reviewed the installation of the process systems in the DCF to determine that the systems were in accordance with the process drawings.

(2)

Observations and Findings The inspector selected components and instruments which had been identified by the licensee as having a safety function.

This identification was based on the Active Engineered t

Controls (AEC) draft list or the hazards analysis evaluation.

The inspector then took the P& ids for the various systems (vaporization, conversion, acid recovery, etc.) and walked down the systems for process line 1 to verify that the equipment was installed and was shown on the P&ID. The inspector also traced out flow pathways to confirm that the process lines were as shown.

All of the valves, instruments and major components were installed as shown. The inspector also verified that switches or contacts which are used to align moveable equipment and permit valves to open when the equipment is in proper alignment (limit switches) were installed as shown.

In the Hydrofluoric Acid Facility, the inspector walked down the common system for process lines 1 and 2.

The inspector cbserved that a system modification had been made which incorporated an additional in line uranium monitor to the common process header. This provides two inde mndent measurements of uranium concentration before t1e recovered i

acid is released to non favorable geometry tanks as the acid recovery line from each process line also has an in line monitor.

In reviewing the systems for the powder cooling hoppers, the inspector observed that each hopper has a pressure relief valve to prevent overpressurization of the hopper.

However, there is a manually operated valve located downstream of the relief valve where the discharge line connects into a vent i

header. The inspector questioned this installation because with the manual valve in the " closed" position, the relief valve would not function properly.

Licensee representatives stated that all of the lines connecting to the vent header had isolation valves so the vents could be closed when a powder collection container had to be removed.

However, they agreed that the relief valve discharge should not be

)

blocked and stated that the subject valves would be locked

11 open until they could be removed.

i (3)

Conclusions The identified AECs and related instrumentation were a

installed as shown on the P& ids.

The installation of a second in line monitor for recovered acid provides additional assurance that nuclear safety limits for the tanks are maintained.

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c.

Criticality Warnina System l

(1)

Inspection Scope i

The inspector reviewed the adequacy of the installation of criticality detectors and the status of system completion.

(2)

Observations and Findings j

During walkdown of the process systems, the inspector also 1

j observed the location of the criticality warning system detectors to assess if they provided adequate coverage. The i

inspector reviewed the figures in Nuclear Safety Instruction 0.4.0 and compared the actual installation locations. Two detectors were found to have been installed in different i

locations than shown in the figures although they were within approximately ten feet of the location shown.

Licensee representatives stated that the figures would be revised to show the actual location during the current i

revision.

The process systems and major components are located in individual rooms. However, all but three of the detectors are located in open areas outside the equipment rooms. The j

structural walls will provide attenuation of radiation. The inspector asked for the documentation that demonstrates that the detectors are capable of meeting the requirements of 10 CFR 70.24 for criticality warning systems.

Licensee representatives stated that the analysis to demonstrate the adequacy of the location of the detectors had not been completed but would be performed.

(3)

Conclusions The adequacy of the criticality warning system has not been demonstrated.

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12 d.

Air Samplina System (1)-

Inspection Scope The inspectpreviewed the basis for the installation of the air sampling system.

(2)

Observations and Findings Stationary air samplers (SAS) are installed in various locations to monitor airborne concentrations and to assess exposures of workers. The samplers have been insta1>d throughout the DCF.

The inspector discussed how the locations were determined and how it was determined that values derived from the samplers would be representative of the actual exposures of the workers.

Licensee representatives stated that the currcs.c locations for the SASS was based on observations of the equipment and the areas where workers would be relative to potential sources of airborne material. These were not i

necessarily the final locations as tests will be made of air flow patterns once the final balancing of the ventilation is complete. Checks will also be made as equipment, such as the va mrizers, are heated up.

SASS will be relocated based on smo(e tests. Until the representativeness of the SAS i

values is determine, workers will also wear portable air samplers to assess their actual exposures.

f (3)

Conclusions The stationary air sampling system has not yet been I

demonstrated to provide representative sampling data.

4.

Functional Testina (88025) a.

Test Administration and Control (1)

Inspection Scope The inspector reviewed the administrative controls for preparing and conducting functional tests of AECs.

(2)

Observations and Findings The primary document is Practices and Procedure (P/P) 10 12, r

" Functional Test Instructions", which defines the requirements for the procedure and the test program.

Section Administrative Routine (SAR) 350 28 " Functional i

Test Administration" had been issued by the manager of the Chemical Product Line to implement the functional test program. On March 5, 1997, revision 5 to the SAR was issued i

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which makes it applicable to the Dry Conversion Product Line

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as well.

Functional testing for the DCF will be performed f

in accordance with the SAR.

(3)

Conclusions Adequate administrative controls are in place to implement i

the functiwal test program.

b.

Functional Test Instructions i

i (1)

Inspection Scope The inspector reviewed the status of the functional test j-instructions (FTIs) to perform tests of AECs and other i

safety interlocks.

(2)

Observations and Findings During the ins xction period no FTIs for vaporization.

conversion or iF recovery had been approved or conducted.

The AEC List was being revised and up dated.

The FTIs will change based on the AEC list. Also, the program code for j

the process control system was being revised to implement centrols over accessing and modifying the set points or actions controlled by the process control system.

Tests had been conducted on portions of the system controlled by programmable controllers. However, some controllers were being changed and the code was also being revised based on the initial test results. These tests will have to be conducted again.

j Properational tests of the system using the vendor's procedure no. U01.1320, ' Manual for No Load Tests" were scheduled to begin for the vaporization portion of the system but this is dependent on completion of the revision of the program code for the process control system.

(3)

Conclusions Functional testing of the safety interlocks and controls is lagging due to changes in the process control system code and changes in the scope of the AEC list.

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p 14 5.

Process Safety Analysis (88020) a.

Analysis Proaram (1) Inspection Scope The inspector reviewed the administrative program for conducting the safety analysis, documenting the findings and resolving the findings.

d (2)

Observations and Findings In the renewal 3) plication for license SNM-1097, dated April 5, 1996, t1e licensee committed to conducting an Integrated Safety Analysis (ISA) for the Dry Conversion Process as well as other plant areas once a baseline is established. A P/P has been written to implement the ISA once the license is renewed.

r The licensee conducted a Process Safety Analysis for the DCF systems and areas primarily using the Hazard and Operability Analysis (Haz0p) methods. This was in accordance with P/P 80 62, " Hazard and Operability Analysis." Other techniques were used in conjunction with the Haz0p.

The analyses were performed by teams with a wide range of expertise in safety and operations.

For example, the analysis which was aerformed during March 11-13 for the transition work in H0 and the installation of the Dry Recycle Facility consisted of eleven people.

The evaluations of potential hazards and the identification of controls was very detailed and thorough.

Evaluated hazards were then ranked according to the likelihood of occurrence and the severity of the consequence.

A summary of the DCP ISA was submitted to the NRC on February 19, 1997, in support of the license renewal.

(3)

Conclusions The safety analysis was conducted by qualified personnel using generally accepted evaluation methods.

The sdfety analysis was a very thorough in depth evaluation of the facility systems and potential operator actions.

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Safety Analysis Imolementation l

(1)

Inspection Scope l

The inspector reviewed how the safety analysis findings were translated into safety controls.

(2)

Observations and Findings l

In the Safety Analysis worksheets, various items were identified as " safeguards" or actions which would occur when instrumentation sensed an upset condition to preclude the identified consequence.

The inspector selected approximately fifteen of these safeguards from the safety analyses for vaporization, conversion and HF recovery and compared them to the draft AEC list. All of the identified safeguards were listed on f

the draft AEC list and identifed with FTIs to verify that l

the safeguard responded properly.

Verification that the safeguards function properly will be i

reviewed as part of pre operational testing. Those actions which require o>erator actions will be reviewed in conjunction wit 1 the operating procedure review.

(3)

Conclusions The safeguards appeared to be addressed in the test program.

However, the AEC list and FTIs are still in draft.

l 6.

Exit Interview Summary (88020)

On March 21, 1997, the inspection scope and findings were summarized with licensee representatives.

The inspector discussed in detail the areas inspected, the findings and concerns which had been identified.

There were no dissenting comments expressed by licensee representatives.

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m 16 ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel

• H. Chilton, Manager, Joint Conversion Project

• T. Flaherty, Manager, DCP Operation

• R. Foleck, Sr. Licensing Specialist C. Kipp, General Manager, GE NEP

• J. Kline, Manager, Powder Product Line A. Mabry, Program Manager, Radiological Safety

• R. Martyn, Manager, Material Control and Accountability C. Monetta, Manager, GE NE Environment, Health & Safety

• S. Murray, Team Leader, U0 Production Team 2

• L. Paulson, Manager, Nuclear Safety

• L. Quintana, Manager, Fabrication Product Line

• R. Reda, Manager, Fuels and Facility Licensing

• G. Smith, Team Leader, FM0 Maintenance Support

• D. Snell, Manager. Service Components Product Line (Acting GM GE-NEP on March 21, 1997)

C. Tarrer, Team Leader, Configuration Management & ISA C. Vaughan, Project Manager EH&S New Facility Licensing / Safety

• Attended exit meeting on March 21, 1997.

INSPECTION PROCEDURES USED IP 88010 Operator Training / Retraining IP 88020 Operations Review IP 88025 Maintenance / Surveillance Testing LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None 1

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17 LIST OF ACRONYMS I

AC Area Coordinator AEC Active Engineered Control CFR Code of Federal Regulations i

- ChPL Chemical Product Line t

CR Change Request CSA Criticality Safety Analysis r

CWS Criticality Warning System

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DCF Dry Conversion Facility t

i DCP Dry Conversion Project l

ECC Emergency Control Center l

EH&S Environment, Health & Safety j

l EMT Emergency Medical Team l

EN Event Number ENUSA Empresa Nacional del Uranio, SA ERT Emergency Response Team o

FM0 Fuel Manufacturing Operation i

FTI Functional Test Instruction GE-NE General Electric Nuclear Energy j

GE NEP General Electric Nuclear Energy Production l

HazMat Hazardous Materials i

HF Hydrogen Fluoride at Hydrofluoric Acid IFI Inspector Follow up Item IP Inspection Procedure IR Inspection Report j

ISA Integrated Safety Analysis i

JCC Joint Conversion Company KGS Kilograms MC&A Material Control & Accountability NCS Nuclear Criticality Safety i

NCV Non Cited Violation NRC Nuclear Regulatory Commission NSI Nuclear Safety Instruction n5R/R Nuclear Safety Requirements / Release ONHSS Office of Nuclear Materials Safety and Safeguards OP Operating Procedure OR Operations Resource PA Public Address P/P Practices & Procedures P&ID Piping and Instrumentation Diagram RP Radiation Protection l

SAR Section Administrative Routine l

SAS Stationary Air Sampler i

SNM Sgcial Nuclear Material SSR Software Service Request TOI Temporary Operating Instruction UF Uranium Hexafluoride Ulk Unusual Incident Report U0 Uranium Dioxide 4

USkC U. S. Enrichment Corporation l

P 4

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