ML20140E657
| ML20140E657 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 06/06/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20140E632 | List: |
| References | |
| 70-1113-97-04, 70-1113-97-4, NUDOCS 9706120169 | |
| Download: ML20140E657 (29) | |
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i U. S. NUCLEAR REGULATORY COMMISSION j l
REGION II i
Docket No.: 70-1113 i l
-f License No.: SNM-1097 l Report No.: 70 1113/97-04 l
l Licensee: General Electric Company i l- l Facility: Nuclear Energy Production j l
r Location: Wilmington, North Carolina
- Dates: March 26 - 28, 1997 April 7 11, 1997 April 29 - May 9, 1997 ,
Inspector: G. L. Troup Sr. Fuel Facilities Inspector Approved by: E. J. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety - '
Enclosure 9706120169 970606 F PDR ADOCK 07001113 C PDR
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- t t i EXECUTIVE
SUMMARY
General Electric Nuclear Energy Production ,
NRC Inspection Report 70 1113/97-04 l I
l This routine, announced inspection was focused on the status of the new Dry *
- Conversion Facility (DCF), including operations, completion of construction,
- functional testing of systems and approval of various documents required for operations. Review of previously identified items and reported occurrences was e
- also conducted. A' deep back shift inspection was conducted on May 4. The !
inspection was focused on the safe operation of the facility. '
1 Within the scope of the inspection, no violations were identified. Three new :
4- inspector follow up items (IFIs) were opened. !
s Plant Operations I
e Actions to resolve an improperly identified shipmen:. Of radioactive ;
material from a foreign shipper were completed. l e Actions to identify the cause of failure in the criticality warning system in the DCF and to resolve the issue with the supplier were prompt and thorough.
e During the inspection period, a flashback fire in a sintering furnace and a leak from a chemical process tank occurred. Both events were still under investigation at the end of the inspection period.
l Dry Conversion Facility Construction e Installation of the roof, the leak detection system and the lightning )
dispersion system has been completed. A final review and acceptance of :
the installation by the constructor has to be completed.
e Installation of process line 2 and acid recovery line 3 were verified to have been completed in accordance with the system drawings.
e The effluent monitoring system for the building exhaust was' modified to remove sharp bends. The flow meters were replaced with meters compatible with the licensee's calibration equipment.
e Uranium process monitors in the acid recovery facility have been calibrated. Other process monitors for process line 1 were also calibrated.
Dry Conversion Facility Testina e The vendor's No Load test was conducted twice, an initial test and a conformatory test following modification of the Distributed Control System software. The Start Up test began during the inspection.
e Functional tests were conducted on Active Engineered Controls in process line 1 and lines 1 and 2 in the acid recovery facility.
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1 Hanaaement Controls e An extensive Readiness Review was conducted by a forty member group.
- Findings were resolved or approved by management to accept "as is."
e The Wilmington Safety Review Committee reviewed the findings and l resolution of findings of the Integrated Safety Analysis, the Readiness Review and other pre operational audits. Approval for operation was given on May 9, 1997.
e An electronic document system has been implemented for the DCF. t Operating procedures, technical reports and functional test instructions were placed on the system after approval.
e Industrial safety and chemical safety hazards analyses were completed and the requirements approved.
e The licensee has established controls for the maintenance of safety l
controls in the DCF. !
Trainino e The licensee has implemented a training program for new operators in the I Chemical Area and Uranium Recovery.
Attachments Partial List of Persons Contacted-Inspection Procedures Used List of Items Opened Closed and Discussed List of Acronyms l
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- l REPORT DETAILS i Summary of Plant Status On March 28, 1997, R. Nardelli, President, GE Power Systems and S. Specker, President, GE Nuclear Energy (GE NE), were onsite to review the status of the Dry Conversion Facility (DCF) and to review facility operations.
On An: ' 25, 1997. C. Reda, Product Manager, Fuel Components, was appointed the Manager, GE-NE Quality, effective April 28. The former manager was appointed to a msition with GE Motors and Industrial Systems. A replacement as the Product _ine Manager, Fuel Components will be named later.
On April 28, 1997, dedication ceremonies were held for the DCF. This coincided with the meeting of the Board of Directors meeting of Japan Nuclear Fuels (JNF). JNF is a minority owner of the Joint Conversion Company (JCC),
which is the owner of the DCF.
Effective April 28, the DCF was designated a radiologically controlled area, in preparation for start-up activities with Uranium.
During the periods of inspection, normal fuel production activities were being conducted, including uranium recovery and waste processing operations.
Other NRC inspections and activities during the inspection period were:
Environmental Protection and Waste Management. W. Gloersen, Region II, March 24 27, 1997, Inspection Report (IR) No. 70 1113/97 03.
Radiation Protection and Fire Protection, A. Gooden and W. Tobin, Region II, April 14 18, 1997, IR 70 1113/97-05.
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- 1. Review of Previous Events (880?0)
- a. Improper Material Shipment (1) Inspection Scope The inspector reviewed the circumstances involving the receipt of improperly labeled material from a foreign shipper. l (2) Observations and Findinos On March 7,1997, while unloading a seavan shipping 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 tampersafe seals. The employees notified the cognizant personnel. Details of the licensee's actions are discussed in IR 70 1113/97 02, Paragraph 1.b. At the conclusion of
i that inspection, the licensee was awaiting receipt of the investigation report from the shipper (ENUSA). Corrective ,
actions were identified in Unusual Incident Report (UIR)
DCP 9701.
On March 26, 1997, ENUSA forwarded a copy of their investigation report and the corrective actions they had initiated as a result of this incident to the licensee. The licensee's review of the ENUSA report concluded that '
adequate corrective actions had been taken. t The licensee completed the actions identified in UIR DCP- t 9701, such as entering the materials received into the material accountability system. The licensee has closed the UIR.
(3) Conclusions ,
1 Corrective actions regarding the improper shipment were completed.
The shi)per has completed the investigation and initiated accepta)le corrective actions.
- b. Criticality Warning System Horns (1) Inspection Scope The inspector reviewed the cause and corrective actions taken after horns in the DCF failed to activate during a test of the warning syst!m.
(2) Observations and Findinas On March 25, during a test of the alarm horns in the DCF, the horns in two sections (consisting of two loops in the circuit) of the facility did not activate and sound. When a failure like this happens, a failure alarm is supposed to sound in two offices and the circuit is sup>osed to shift to a back up board to maintain operability. T11s did not -
occur.
An investigation determined that the tailure had occurred in an amplifier board. A contractor service representative replaced the amplifier board and the system was successfully tested.
On April 8, a licensee representative took the amplifier board to the manufacturer's facility and witnessed the investigation as to why the board did not function properly.
3 The manufacturer was not certain why the board had failed because it had passed two tests before being shipped: (1) a test of the individual amplifier board, and (2) a test of the assembled unit.
Under the observation of the licensee representative, the manufacturer conducted a series of tests of the board and determined that the problem was the "K2" relay. It was determined that a connector pin on the relay was broken at about half of it's length. A new relay was installed and the board was satisfactorily tested. It was not certain when the connector pin might have broken. The board was returned to the plant as a spare unit.
The licensee representative concluded that the broken pin was an isolated failure and was not indicative of a generic or design problem, which would have required reporting under the requirements of 10 CFR 21.
(3) Conclusions The licensee's efforts to identify the cause of the failure was very thorough.
The inspector concurred with the licensee's assessment that this was an isolated problem and not a generic problem.
- c. Gadolinia Furnace Fire (1) Insoection Scope The inspector reviewed the cause and corrective actions taken following a fire in a sintering furnace.
(2) Observations and Findinas On April 19, 1997, a small fire occurred at the entrance to a sintering furnace in the Gadolinia shop. An empty pellet boat had been loaded into the loading box. A flashback occurred. A pressure relief device on the top of the furnace opened, reset and then opened again. The second time the device opened, flames erupted through the opening and set a alastic flow meter on fire. When an oprator observed t1e fire, he attempted to put out the flames with his hand. During the event, the operator received a flash burn to his face and a burn on his hand from extinguishing the fire on flow meter. He was subsequently treated at an offsite medical facility and released.
Pending an investigation into the cause of the fire, the furnace was purged with nitrogen to remove the combustible atmosphere and the temperature reduced (" idled").
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4 The initial review indicated that a malfunction of a timer may have initiated the action. When a pellet boat is loaded, the outer door of the loading box opens to permit ,
entry, then closes. With both the outer and inner doors '
closed, the box is purged with nitrogen for a s)ecific time (controlled by the timer) to remove air in the aox. At the end of the. purge, the inner door opens to >ermit the boat to ;
enter the furnace. In this instance, if t1e inner door ~
opened before the purge was complete, air in the box would
- react with the hydrogen in the furnace, causing the fire. <
The licensee initiated a root cause investigation into the 4
event and an VIR. At the conclusion of the inspection, this investigation had not been completed. ,
I (3) Conclusions The results of the investigation and completion of any I corrective actions will be reviewed later. This will be tracked as Inspector Follow up Item (IFI) 97 04 01.
- d. Hydrolysis Tank Leak (1) Insoection Scope The inspector reviewed the cause and corrective actions I taken following a leak in a chemical process tank. l (2) Observations and Findinas On May 5,1997, an operator in the Chemical Area observed a .
" cloud" adjacent to the hydrolysis receiver tank on Line 1. l He contacted the Chemical Control Room by telephone, then l helped get personnel out of the area. Control Room operators stopped the flow of UFs gas to the tank, then pumped most of contents to the a hydrolysis storage tank.
Response personnel, using respiratory protection, entered the area, verified that the leak had stopped, and initiated clean up activities. The area was cleared and released for normal access in about an hour, Special air samples were collected and both the stationary air samplers (SASS) and the stack sampler were collected for evaluation. Personnel 3 who had been in the area were placed on a special bioassay !
program and restricted from the area. Subsequent evaluation l of the samples showed that the highest exposed individual had an intake of 3.6% of the regulatory limit based on a weekly intake and there was no potential that the Annual Limit of Intake (ALI) had been exceeded by any of the workers present. All air sample results and the stack ,
sample were less than an.v regulatory limit. i
5 Inspection of the tank revealed a small hole in the side of the tank. When the tank was removed, several depressed areas on the inside of the tank at approximately the same level as the hole wei'e noted. The evaluation was these depressions and the hole were caused by erosion produced by the UFs gas coming from a misaligned dip tube. The dip tubes are installed vertically, but there is nothing to hold them in place in the holes in the tank top, so one or both could be tilted or " cocked."
A new tank was installed. To prevent the tilting of the dip tubes, an alignment fixture was designed and installed. The tank was returned to service on May 6. The alignment fixture was also installed on other process, as necessary, lines that same week.
The licensee initiated a root cause investigation team and also planned to inspect the hydrolysis receiver tanks on other lines. At the conclusion of the inspection, these activities were still being conducted.
(3) Conclusions The results of the investigation and completion of any corrective actions will be reviewed later. This will be tracked as IFI 97 04 02.
- 2. Dry Conversion Facility Construction (88020)
- a. Roof Construction (1) Insoection Scope The inspector reviewed the status of the completion of the roof membrane and the installation of the leak detection system.
(2) Observations and Findinas 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 U0 2 powder is produced or handled. A principal 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 barriers 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.
6 The Engineer / Constructor (E/C) roof expert reviewed the construction of the roof for the DCF, the HF facility, the :
shipping container warehouse, and the FM0X mezzanine roof, ,
all of which have been installed by the E/C. A number of problems were documented in a letter dated February 28, 1997, for correction.
The inspector toured the DCF roof with a licensee ;
representative and observed that most of the identified problems had been corrected. However, one spot was identified where a sharp object was located under the up membrane, which could cause penetration of the membrane.per The area was marked for correction. ,
The licensee representative stated that the E/C's roof expert would be asked to do a final review of the roof and document its acceptability.
A system to disperse lightning has been installed around the building roof and on the ventilation exhaust stack. The inspector observed that the supports for the lightning dispersion system were connected to the building structure and did not penetrate the integrity of the membrane.
As part of the DCF roof construction, a leak detection system is installed to identify leakage through the first ,
membrane and the upper slab. Tha inspector observed that i the drain pipes have been installed in three locations on !
the drain trough (IR 70 1113/97 02, Paragraph 3.a). On i April 9, the inspector observed that the lower collection section (which would provide visual indication of leak detection) and isolation valve had been installed on each drain pipe. This completes the installation of the leak i
detection system.
(3) Conclusions The construction of the DCF roof is complete. Final inspection,and acceptance following repair of any designated areas remains.
- 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.
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7 (2) Observations and Findinas 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 Controls (AECs) list in the Technical Reports or the hazards analysis evaluation.
The inspector then took the Piping & Instrumentation
, Diagrams (P& ids) for the various systems (vaporization, conversion, acid recovery, etc.) and walked down the systems for process line 2 and the HF acid recovery for process line 3 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.
The inspector noted that the equipment numbers for the vaporizers in process lin's 2 did not agree with those shown on the P& ids. The equipment number for the vaporizer associated with number 1 vaporizer shown on the P&ID was physically on number 2 vaporizer and vice versa. Licensee representatives had previously identified this condition i during system walk downs. They are investigating whether the nameplates can be switched or if the P&ID equipment J numbers should be changed to conform to the actual installation.
4 (3) Conclusions The process lines were installed as shown on the P& ids. ;
Instrumentation and critical valves were as described in the AEC lists and the hazards analyses.
- c. Effluent Monitoring Equipment (1) Insoection Scope The inspector reviewed the actions taken to correct l identified deficiencies in the sampling system for the DCF I and HF building exhaust system.
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(2) Observations and Findinas !
During the review of the sampling system for the building 4 exhaust systems, the ins)ector observed that the sampling :
probe line had several slarp bends. This and other observations were documented in IR 70 1113/97 03, section II.C.2.
The inspector observed that the sample line from the DCF exnaust stack had been replaced with a line with a long, curved bend so there were no sharp turns and that the air flow measurement probes had been installed. The inspector also observed that flowmeters manufactured by Wallace & ,
Tiernan had been installed in the DCF and HF exhaust '
, sampling systems. This change was made because the licensee's calibration equipment is compatible with Wallace ,
& Tiernan flow meters.
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On May 8.1997, a velocity profile measurement was performed on the DCF exhaust duct. Two sets of measurements were taken, one set about 90 around the duct from the other.
Velocity measurements showed relatively uniform flow across the duct in both directions, indicating no major obstructions or conditions which would affect the sam)le i collection. Based on the velocity profile, flow in t1e exhaust is turbulent, confirming the licensee's assessment that only one sample probe is necessary, q (3) Conclusions The sampling systems have been modified to provide proper sample collection.
The air flow in the exhaust duct is uniform and turbulent.
- d. Instrument Calibrations l
l (1) Insoection Scone l
The inspector reviewed the calibrations for selected instruments which are part of AEC circuits.
(2) Observations and Findinas Each vaporizer includes a monitoring system which includes an analyzer for UF , The atmosphere in each vaporizer is continuously monitored during operation for the evidence of which would indicate a leak from the cylinder or the :
UF pip ,ing system. According to the Technical Report (TR) for !
vaporization (TR 1331), the in line monitor is part of an AEC which activates certain controls automatically if the limit is exceeded. (Functional testing of the AECs is
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9 discussed in Paragraph 3.)
The inspector reviewed the calibration records for the UF, detectors for the vaporizers on Line 1 in the Maintenance Planning and Control (MPAC) computer record :.,ystem. Both detectors were calibrated on April 26, 1997, and the 1 associated Work Orders were closed in MPAC on April 27. The MPAC records did not have detailed information about the calibration but showed that the work had been completed.
Licensee management stated that the detailed information
, concerning the calibration of these detectors, as well.as l several other instruments, would be added to the MPAC record. {
There are several UF, detectors installed in the vaporizer i rooms to detect any gas leaks from the system outside of the vaporizers. These detectors fail when detecting UF, so they cannot be " calibrated" in the normal sense.
The HF facility system has four Uranium monitors (U-monitors) one in each process line downstream of the condenser and a common detector in the line to the HF
- collection tanks. The inspector reviewed the records of the calibrations of the U monitors.
All fivefour U monitors solutions of Uranium were enriched calibratedtoon 5t HagU, the maximumh 22, 19 enrichment authorized for DCF. Although materials received in HF from Conversion will be virgin material (no decay daughter products), the calibration was checked with aged material (that which contains the daughter products) to assure that the calibration would correctly identify such materials. The basic scale was also checked with two solutions around 4% enriched materials. Blank samples (using water) and the internal sources were also used in the calibration. Following determination of the monitor output with these solutions, set points were determined using a linear regression calculation.
Uranium concentration limits for the HF tanks were set at l 100 parts-per million (
i safety considerations. pam), based ollowing theoncalibrations, nuclear criticality it was l determined that the span of associated instruments meant that the upper limit of the span was equivalent to 23 ppm !
Uranium. Appropriate procedures were being revised to i reflect this limit. i t
Under normal conditions, U monitor Scale #1 is used. The monitor also has a second scale (Scale #2) which was also checked with natural Uranium and an enriched solution about 4% to verify that the monitors functioned properly on this setting.
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10 (3) C_gnelusions The UF s monitors for the vaporizers were calibrated but !
documentation needs to be completed.
The U-monitors in the HF building were thoroughly calibrated l and process limits were revised to reflect instrument :
limitations. ;
- 3. Pre 00erational Testina (88020. 88025)
- a. Pre Operational Tests !
(1) Insoection Scooe i The inspector reviewed the completion of the system pre- l operational tests to verify that equipment check outs and i system leak tests had been completed.
l (2) Observations and Findinas The equipment contractor developed two sets of procedures for initial testing. The vendor's procedure no. U01.1320,
" Manual for No-Load Tests," dated August 29, 1996, was used for the no-load tests. These tests included checks on ,
individual pieces of equipment, such as electrical checks on I motors, check for proper rotation of motors and equi ament, i verification and adjustment of valve movement, threslold l measurements for measurement, interlock and alarm devices.
l No Load tests for vaporization began on March 24. Tests for J conversion began on April 1. Other parts of the facility were also tested. During these tests, numerous problems were encountered with Distributed Control System (DCS) software.
This required numerous modifications of the software code.
As a result of these numerous changes, the licensee conducted the No Load tests a second time. After each )
portion of the No Load test was successfully completed the i second time and the software was verified, the code was
" locked" and placed in the Configuration Management program.
After the software was " locked," functional tests were conducted to document that the controls functioned, as described in Paragraph 3.b.
The vendor's procedure no. U10.1320. " Start Up Manual,"
dated December 4, 1996, was used for start up testing. As part of this test involves testing with licensed material (State of North Carolina license), the manual was issued as !
an attachment to Temporary Operating Instruction S01 1332.05. "DCP Start up Testing" and approved in accordance with the licensee's administrative procedures.
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11 Start up testing began on April 17 with the conduct of leak tests in vaporization. The inspector observed selected tests in the Control Room and determined that the systems ;
were functioning as stated in the Start Up Manual. Start up ;
testing of the facility was still in progress at the end of ,
the inspection period.
(3) Conclusions No-load testing was satisfactorily completed. Software changes necessitated that tests be conducted a second time to verify the all set points and interlocks were proper i before releasing the system for functional testing.
Start Up testing started using an approved procedure.
- b. Functional Tests '
l (1) Inspection ScoDe J The inspector reviewed the completion of the functional test instructions (FTIs) for AECs, and, when possible, witnessed the performance of the tests.
(2) Observations and Findinos As discussed in IR 70 1113/97 02, Paragraab 5, an Integrated Safety Analysis (ISA) was performed for t1e DCF. As a result, a number of AECs were identified. The licensee's internal procedures require that AECs which are nuclear criticality safety controls must be periodically tested in accordance with approved FTIs.
FTIs were identified for designated AECs and included in the TRs. This list was revised several times, based on the ISA and Readiness Review (Paragraph 4.a.). The FTIs also were the final tests to demonstrate that the software for the DCS functioned properly, as required by P/P 12015.
After the DCS software was modified following completion of the No Load tests for vaproization and conversion (Paragra)h 3.a.(2)), many of the FTIs were conducted to verify tlat the systems functioned as required. The inspector observed the conduct of six of these preliminary tests on March 27. All controls functioned as required.
The inspector reviewed numerous FTIs in draft form and detennined that the test sequences and actions were l
consistent with the requirements specified in the AEC lists.
On April 22 and 23, the license conducted the official functional tests for the AECs in process line 1 vaporization i (a total of 14 tests), conversion (15 tests), powder outlet 1
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(3 tests) and the HF facility (10 tests). On April 28, the inspector reviewed the FTIs and the results for vapo; nation. The inspector noted that FTI 1331 8, which ,
was a test for the cold trap, was signed off as conducted on ,
April 23. However, the approval record for that test !
document showed that the test was not approved until April 29. When the inspector brought up this point to the
. licensee, the test was conducted satisfactorily on May 1 and :
a was observed by the inspector, l
4 The inspector reviewed the completed FTIs for conversion, I powder outlet and HF during April 29 30. All of these FTIs were approved prior to the test. Changes to the FTI made in !
. the field were reviewed and approved in accordance with the 4 administrative procedure. The inspector determined that the i FTI results satisfied the requirements specified in the AEC
- l. lists.
During the conduct of FTI 1332-15, which verifies that the
. recycle hatch valves on the kiln operate so that only one i valve is open or can be opened at a time, both hatch valves 4
o aned at the same time under one of the test sequences.
T1e ' interlock should have prevented one valve from opening when the other valve was open. After trouble-shooting the i
problem and resolving the problem, the FTI was conducted on May 8 and was observed by the inspector. The test was conducted satisfactorily. The same logic applies to the valve sequence on the powder outlet from the kiln. On May 8, FTI 1333-2 was conducted again and the interlock was found to function properly.
The inspector noted that all of the completed FTIs had I changes made in the field. These FTIs will be used for the testing of the other process lines as well as for the aeriodically (annual or after maintenance) required tests.
_icensee representatives stated that the FTIs would be revised to reflect the field changes and any other lessons learned during the start-up testing (3) Conclusions Functional tests were performed and demonstrated proper operation of the AECs.
After a problem in an interlock sequence was identified, the ,
licensee retested a similar interlock was retested to check '
for the same problem. The other interlock functioned properly.
13 FTIs need to be revised to reflect lessons learned during initial testing.
The problem with conducting a test with a draft (unapproved) procedure is addressed further in Paragraph 5.a.(2).
- 4. Manaaement Controls (88005)
- a. Readiness Reviews (1) Insoection Scope The inspector reviewed the findings of the Readiness Review and the ISA to verify that results had been addressed and resolved. ,
(2) Observations and Findinas To provide an independent assessment of the facility status and readiness for operation, the licensee conducted a Readiness Review. The review was conducted by forty persons re3 resenting a wide range of skills. Team members came from NE), other GE facilities, contractors from other companies and several former NEP employees. Three main areas were addressed: operations, maintenance, and environmental, health and safety (EH&S).
The Readiness Review was conducted March 17-21, 1997.
Approximately 290 findings were identified, although some were considered " major" and others were of lesser significance. Each finding was assigned a priority rating and a person designated with the responsibility to resolve the finding. Several of the team members later formed a team to review the corrective actions on the identified items. Each item was tracked in a data base to assure completion or resolution.
The findings of the Readiness Review were presented for management review on April 22, 1997. All items were completed or accepted on May 9.
As discussed in IR 70-1113/97-02, Paragraph 5, the licensee had conducted an ISA for the DCF. Findings were classified in three levels of risk. For those considered to present
" moderate" risk, they were further classified as "fix" or
" accept." The inspector reviewed the summaries for "high" risk items in vaporization, conversion, and acid recovery and selected various items. The inspector then determined that the actions had been completed to resolve the finding.
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14 (3) Conclusions The Readiness Review was conducted by a team of knowledgeable individuals. It represented a very detailed and thorough review of the facility and the state of .
- readiness to operate. ,
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Findings were tracked to assure completion. Corrective actions were inspected to verify completion. All findings ,
were resolved.
- b. Management Review of Findings (1) Inspection Scope The inspector reviewed the results of the management review of the resolution of items for readiness to operate.
(2) Observations and Findinas Part I, Chapter 2.- section 2.3.1 of the License Application establishes the Wilmington Safety Review Committee (WSRC).
One of the assigned functions of the WSRC is to review nuclear and industrial safety practices applied to major changes made or proposed in authorized plant activities.
P/P 40-1, "Wilmington Safety Review Committee" includes new facilities or major changes to existing facilities.
On A)ril 22, 1997, the WSRC reviewed the findings of the ISA whic1 had been classified as " moderate risk no action."
the findings of the Readiness Review and the findings of 3' several pre operational audits. The WSRC accepted the recommended actions for most of the actions. However, WSRC disagreed with the recommended actions for seven findings.
Additional action was required for these items.
On May 5,1997, another WSRC meeting was held to review the i status. Not all actions were accepted. On May 9, 1997 I another WSRC meeting was held. Corrective actions were j accepted and the WSRC accepted the DCF as ready to operate.
(3) Conclusions The audit findings and corrective actions were reviewed and accepted in accordance with the license requirements. The WSRC review was active in that recommended actions were not accepted without further action.
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I c. Audits (1) Inspection Scope The inspector reviewed the results of the most recent ,
Nuclear Safety audit.
(2) Observations and Findinas Part I, Chapter 2, section 2.1.8 of the License Application states that quarterly audits of plant operations will be i conducted by the nuclear safety staff. The audit for the !
first quarter, 1997, was conducted during the period February 24 March 4. .
l The inspector reviewed the audit report and determined that the audit was conducted by qualified auditors and was in accordance with procedural requirements. No items of non-compliance were identified. Areas of concern were identified to the cognizant managers and resolved.
(3) Conclusions The first quarter audit was conducted as required. No non-compliances were identified.
- 5. Procedures and Documentation (88020_).
- a. Operating Procedures (1) Inspection Scope The inspector reviewed the status of approval for operating procedures and also reviewed the contents of selected procedures.
(2) Observations and Findincs Operating procedures (designated Standard Operating Instructions S0Is) for the DCF are in the electronic form.
Procedures are accessed through the electronic system rather than using paper copies. P/P 10 09, " Operating Procedures (ops) FM0" was revised to saecify that electronic procedures are approved for t1e DCF. The format for such arocedures is specified in SAR 350 30, " Writing Operations
)rocedures."
When an operator logs into the system, a dialogue box informs him of any procedure changes. The operator then reviews the changes, which are highlighted on the screen,
16 and electronically " signs" that the change has been read and understood. The system is monitored to assure that acknowledgments are timely.
The Configuration Management Center (CMC) maintains control over the procedure system and maintains records of the approvals. When procedures are revised, the procedure is released electronically by CMC. Other documents related to DCF are also being placed on the electronic procedure system, such as TRs, FTIs and certain hazards analyses.
P& ids are also being placed in the electronic system. The inspector also reviewed six TRs, which had been approved and released by CMC onto the electronic procedure system.
The inspector observed that documents on the electronic system do not reflect the revision number or show the approvals. This is because the procedure is not released onto the system by CMC until all approvals are documented and placed in the CMC records. Draft procedures or draft revisions are kept in a se)arate electronic file until approved and released to t1e document file. However, there are certain documents, such as FTIs and operator logs, which must be arinted in paper form for use. As identified in Paragrap1 3.b.(2) a copy of an FTI was used which had not been approved was used to conduct a test. After this problem was identified, licensee representatives stated that they would develop a method to assure that paper copies of documents in use in the facility were the latest, approved revision.
Six S0Is were approved and released for the DCF systems.
The inspector reviewed the records in CMC and verified that all had been reviewed and approved as required by P/P 10-09 and that the revisions made were also properly reviewed and approved. One procedure was issued as a TOI to address the start up testing (section 3.a).
The procedures were reviewed and determined to contain recuirements for criticality safety, radiation safety, incustrial and chemical safety, environmental requirements, material control and accountability and quality control.
The procedure format is such that specific cautions or warnings are highlighted in the text at the appropriate position. General requirements and precautions are specified for each safety area in the beginning.
During the course of the inspection, the inspector reviewed drafts of the procedures and identified questions to the authors. In early versions, there were conflicts between procedures or with the Technical Report. These were resolved as the procedures were finalized.
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17 The inspector noted that several S0Is have been revised l l based on changes identified during testing. The inspector i
verified that selected revisions had been approved at the same level as the original issue. TRs will also be revised to reflect final system changes and instrument set-point revisions.
(3) Conclusions S0Is were prepared, approved and revised.in accordance with administrative procedures.
S0Is contain adequate safety requirements. ;
I The method to assure that only current and approved paper copies of documents are used in the facility will be tracked as IFI 97 04-03. l
- b. Hazards Analyses (1) Inspection Scope The inspector reviewed the industrial safety and l radiological safety analyses which had been prepared for the j DCF.
(2) Observations and Findinas l The licensee conducts a Job Hazards Analysis (JHA) for new processes and operations. The JHA evaluates industrial safety conditions, such things as weight handling, use of fork lifts, hot conditions, etc. If the process or operation involves a new chemical or chemical process, then i a Chemical Job Hazard Analysis (CJHA) is performed. The CJHA addresses safety clothing and equipment, handling and J storage requirements and associated items. Both JHAs and CJHAs were preaared for the DCF in addition to the ISA and ;
the Readiness leview.
A total of thirty two JHAs were prepared and approved for the DCF. All but one were approved on April 3, 1997: the last one was approved on April 10. Several of these JHAs covered generic safety issues, such as use of fork lifts and weight handling but were issued as specific JHAs for DCF.
1 Fourteen CJHAs were approved on April 11, 1997, for the DCF.
These included chemicals which are new to the facility, such as the refrigerant for the cold traps.
Additionally, the Radiological Safety function performed nine Radiological Safety Assessments (RSAs) addressing radiological considerations with natural Uranium. One RSA l
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- l 18 4 was a finding of no impact for the HF facility. The ,
findings from the RSAs were implemented by the preparation ;
and issuance of 27 Nuclear Safety Release / Requirements ,
(NSR/Rs). The NSR/Rs were ap) roved on April 17, 1997. Both the RSAs and the NSR/Rs will )e revised and reissued for enriched Uranium operations. !
The RSAs were loaded in the electronic document system and released on A)ril 29, 1997. In this form, they may be accessed by t1e operators. The inspector observed that copies of the JHAs, CJHAs and NSR/Ss are available in the Control Room.
(3) Conclusions The licensee performed adequate safety reviews for the new facility and established appropriate controls. Requirements were documented and made available to operators.
- c. Maintenance Control (1) Inspection Scope The inspector reviewed the controls that the licensee has established to control maintenance of safety controls in DCF. ,
(2) Observations and Findinas The licensee had established requirements for maintenance in the chemical and fuel fabrication areas. These controls covered the control of work orders, like kind replacement of equipment, and verification of controls after maintenance.
SAR 50 07, " Safety Controls Verification" and SAR 350 08,
" Work Order and Replacement Parts / Materials Procedure for FM0" were revised and issued to make them applicable to the DCF. Controls are equivalent for all fuel operations.
(3) Conclusions The licensee has extended existing controls to the DCF so one system applies to the entire fuel manufacturing operation.
- d. Emergency Procedures (1) Inspection Scope The inspector reviewed the controls to assure that the appropriate procedures and documents are available to personnel in the Emergency Control Center (ECC).
19 (2) Observations and Findinas In the event of an accident or condition that requires that the ECC be manned, personnel in positions to make decisions must have current documents available to them. The inspector asked what documents were being provided in the ECC concerning the DCF.
Licensee representatives stated that a review had been
) conducted to identify the appropriate documents and provided a preliminary list of documents and drawings to be placed i inthe ECC. On May 8, 1997, licensee representatives informed the ins mctor that controlled copies had been i released to the ECC.
l The inspector noted that while the relevant documents and drawings had been provided in the ECC, the remaining question was how it would be assured that controlled copies
- of these documents would be maintained as changes are made to these documents. Licensee representatives stated that i this question was under review to assure that the appropriate documents were available as needed.
(3) Conclusions Copies of applicable documents and drawings have been provided to the ECC for the DCF.
1 The licensee must establish a mechanism to provide controlled copies of applicable documents to the ECC as changes to these documents are made.
- 6. Facility Chanaes and Modifications (88020)
- a. Inspection Scope The inspector reviewed the documentation package for a change made to an existing system in the facility.
- b. Observations and Findinas Change Request (CR) 97.0134 was approved to convert #5 mill-slugger granulator (MSG) to handle materials up to 5% enriched materials (commonly referred to as " hie" materials) from the previous limit of 4% enrichment. This CR replaced the existing granulator, modified the dump station to accept only 3 gallon cans, and modified the hammermill. The CR also did a review to ensure that nuclear isolation existed with shared services.
The CR was approved for installation "at risk" while the nuclear safety analysis was completed on March 20. 1997. Final installation approval was granted on April 1 and final approval to
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20 operate was given on April 3, following completion of FTI 1010.50 F3 which performed checks of the physical ecui) ment so that only 3 gallon cans could go into the mill hood anc t1e pre operational audit. The applicable operating procedure (OP 1010.50) was revised and issued on April 2, 1997. Operator training on the new OP was completed on April 2.
The inspector determined that the nuclear criticality safety analysis had been performed with approved calculational models (GEKEN0) and that controls were appropriate for the system. The nuclear safety analysis was performed and reviewed by qualified personnel. Six NSR/Rs were revised to include the higher enrichment in the HSG. SSR B995 was approved to revise the Material Inventory Control System (MICS) to establish a new station mass limit. If the scale reading of a container is greater than the station limit, MICS will block the transfer of the material into the dump station.
- c. Conclusions The inspector determined that the change in the approved enrichment for #5 MSG was conducted and approved in accordance with license requirements.
- 7. Trainina (88010)
- a. Insoection Scope I The inspector reviewed the licer.cee's program to develop cualified o>erators in the Cnemical Area U%) the Uranium Recovery lnit (JRU) and the powder p*eparation area to replace those operators who transferred to the DCF.
- b. Observations and Findinos In staffing the DCF, experienced operators and maintenance personnel from other plant areas were allowed to bid on the jobs. I When these personnel were transferred to DCF, there was a need to l develop operators to operate exist'ing facilities during the transition period.
To replace the operators who transferred to DCF, some operators '
were ua graded in position levels from "C" to "B" or from "B" to "A." Ex>erienced operators at the Uranium Recovery from Lagoon Sludge (JRLS) facility were transferred back to other operations because of the decreased work load at URLS. Contract workers were also hired to fill some "C" operator positions.
To develop qualified operators, training programs were implemented in the CA and URU. This training involved reading of ops and on-the job training (0JT) for new operators and up graded operators.
New or up graded operators learned their job under the guidance of
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21 l experienced operators. Former operators who were assigned to DCF i worked overtime during their early training phases to help qualify new operators.
r A number of qualification cards were developed for the new '
operators (five for URU floor operators, two for URV Control Room o>erators). Through reading and understanding the ops and 0JT, t1e new operators learned to operate the equipment. In addition to completing the qualification cards for the floor. "A" and "B" operators had to complete the qualification cards for Control Room operators. Each qualification card was com)leted by the trainee and signed by a qualified operator. Once t1e card was complete, the Area Coordinator (AC) had to sign the card, indicating that the trainee was qualified to perform the functions of an operator ,
for that position. 1 Several operator positions require that the incumbent be able to perform radiation measurements using a SAM II instrument.
Training in the operation of the SAM II was conducted and documented by the Material Control (MC&A) group.
- c. Conclusions Training of operators for existing operations was conducted in a prescribed manner, using a devtloped program. The use of former operators to conduct OJT was a strong technique used by the licensee. I
- 8. Information Notices (ins) (92701)
- a. IN 97 20 (1) Insoection Scone l
The inspector reviewed the licensee's actions in response to IN 97-20.
4 (2) Observations and Findinos IN 97-20, " Identification of Certain Uranium Hexafluoride Cylinders That Do Not Comply with ANSI N14.1 Fabrication Standards" was issued on A)ril 17, 1997. This IN stated that a number of model 30 3 UF6 cylinders had been fabricated using a welding procedure which was not qualified to the applicable temperature limits.
Licensee personnel reviewed their records and determined that they did not have cylinders from this manufacturer nor had they received any cylinders from the purchaser. No further action was considered necessary.
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(3) Conclusions The licensee completed appropriate actions to determine that they did not have any of the applicable cylinders.
IFI 97 00 01 is closed,
- b. IN 97 24 (1) Insoection ScoDe i The inspector reviewed the licensee's actions in response to IN 97 24. -
(2) Observations and Findinas IN 97 24. " Failure of Packing Nuts on One-inch Uranium Hexafluoride Cylinder Valves" was issued as a result of a notification received from the U. S. Enrichment Corporation (USEC) on March 14, 1997.
As the result of the initial notification, Region II :
notified facilities of the aroblem. Following the notification, the licensee lad conducted an investigation to determine if they had any of the affected valves. '
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Corrective actions were initiated. These actions were reviewed by the inspector and documented in IR 70 1113/97- ,
- 02. Subsequent to these actions, the IN was issued.
(3) Conclusions The licensee had previously initiated adequate corrective actions on the cylinder valve problem. No additional actions for the IN were necessary.
- 9. Previous Inspection Findinas (88020)
- a. Insoection Scope The inspector reviewed the licensee's actions relating to three violations identified in IR 70 1113/96-12.
- b. Observations and Findinas On December 3, 1996, the licensee reported to the NRC that the tube had failed in the calciner on Line 3, resulting in the accumulation of uranium oxide in excess of nuclear safety limits in the space between the tube and the heat shield. On December 11, 1996, the Manager, GE-NEP sent a letter to the Director, Division of Nuclear Material Safety (DNMS), Region II,
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23 describing the immediate actions taken to resolve the failure of the tube in the calciner for Line 3. As a result of a spcial :
ins >ection (IR 70 1113/96 12) for this failure, three violations i of iRC requirements were identified. !
By a letter dated February 25, 1997, the licensee formally !
responded to these violations. The corrective actions identified '
by the licensee were inspected, in part, during the s)ecial team inspection and as part of two routine inspections. T1e review of ;
the corrective actions was documented in irs 70-1113/97 01 and 70- ,
1113/97-02. All of the corrective actions were determined to have been completed. No further actions are necessary.
- c. Conclusions Based on the review of the licensee's corrective actions, the following violations are closed:
96 12 01 96 12 02 96 12 03
- 10. Exit Interview (88020)
During the course of the ins >ection. meetings were held with cognizant ,
managers to discuss issues w11ch had been identified and make them aware of the inspector's concerns.
On May 9,1997, 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 i were no dissenting comments expressed by licensee representatives.
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1 24 ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED i
Licensee Personnel t
- M. Chilton, Manager, Joint Conversion Project ,
- T. Flaherty, Manager, DCP Operations !
- R. Foleck, Sr. Licensing Specialist l
- R. Keenan, Manager, Site Security & Emergency Preparedness
- C. Kipp, General Manager, GE NEP l
- J. Kline, Manager, Powder Product Line A. Mabry, Program Manager, Radiological Safety <
R. Martyn, Manager, Material Control and Accountability i
- C. Monetta, Manager, GE NE Environment Health & Safety Production Team !
S. Murray, Team Leader, DCF Fac U0,ility Construction R. McIver, Manager,
- L. Paulson, Manager, Nuclear Safety
- L. Quintana, Manager, Fabrication Product Line q
- R. Reda, Manager, Fuels and Facility Licensing i
- G. Smith, Team Leader FM0 Maintenance Support
- C. Tarrer, Team Leader, Configuration Management & ISA K. Theriault, Manager, Fuel Quality and ChemHet Laboratory C. Vaughan, Project Manager, EH&S New Facility Licensing / Safety I
- Attended exit meeting on May 9, 1997.
INSPECTION PROCEDURES USED 1
IP 88005 Management Organization and Control ;
IP 88010 Operator Training / Retraining l IP 88020 Operations Review i IP 88025 Maintenance / Surveillance Testing l IP 92701 Follow up on Previous Items l LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened I
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IFI 97-04 01 Corrective Actions Following Fire in Gadolinia Furnace IFI 97 04 02 Corrective Actions Following Leak in Hydrolysis Tank l IFI 97 04 03 Control of Electronics Documents to Assure Approval Prior to l Use i
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25 Closed IFI 97-00 01 Follow up on Information Notice IN 97-20 on UF 6 cylinder valves VIO 96 12 01 Failure of an engineered controls being capable of performing its specified criticality safety purpose VIO 96 12 02 Failure to provide assurance of the strength of a structure upon which criticality control is directly dependent VIO 96 12-03 Failure to perform required measurement techniques when administratively controlling mass for criticality safety purposes Discussed IFI 96 11-01 Follow-up on long term corrective actions for criticality system warning horns LIST OF ACRONYMS AC Area Coordinator AEC Active Engineered Control CFR Code of Federal Regulations ChPL Chemical Product Line CJHA Chemical Job Hazards Analysis CMC Configuration Management Center CR Change Request DCF Dry Conversion Facility DCP Dry Conversion Project DCS Distributed Control System E/C Engineer / Constructor ECC Emergency Control Center
'EH&S Environment, Health & Safety ENUSA Empresa Nacional del Uranio, SA FM0 Fuel Manufacturing Operation FTI Functional Test Instruction GE NE General Electric Nuclear Energy GE-flEP General Electric- Nuclear Energy Production HF Hydrogen Fluoride or Hydrofluoric Acid IFI Inspector Follow up Item IN Information Notice IP Inspection Procedure IR Inspection Report i ISA Integrated Safety Analysis l JCC Joint Conversion Company 1 JHA Job Hazards Analysis I KGS Kilograms MC&A Material Control & Accountability 1
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i MICS Material Inventory and Control System f MPAC Maintenance Planning and Control !
! NCS Nuclear Criticality Safety :
. NRC Nuclear Regulatory Commission
! NSR/R Nuclear Safety Requirements / Release t
- OJT On the Job Training
- OP Operating Procedure '
i P&ID Piping and Instrumentation Diagram P/P Practices & Procedures ,
l p >m 3 arts per million t i R)
.ladiation Protection -
- RSA Radiological Safety Analysis ,
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SAR Section Administrative Routine !
- SSR Software Service Request j TOI Temporary Operating Instruction
- TR Technical Report -
UF Uranium Hexafluoride j Ulk Unusual Incident Report '
- Uranium Dioxide i U0{.S UR Uranium Recovery from Lagoon Sludge l URU Uranium Recovery Unit i USEC U. S. Enrichment Corporation WSRC Wilmington Safety Review Committee l
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