ML20141J767

Insp Rept 70-1113/97-06 on 970623-27.No Violations Noted. Major Areas Inspected:Status of Dry Conversion Facility, Including Completion of Const,Nuclear Criticality Safety, Chemical Safety & Radiation Protection

ML20141J767
Person / Time
Site:	07001113
Issue date:	08/11/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20141J759	List: ML20141J757 ML20141J767
References
70-1113-97-06, 70-1113-97-6, NUDOCS 9708210235
Download: ML20141J767 (33)

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U. S. NUCLEAR REGULATORY COMMISSION REGION 11 Docket No.: 70 1113 l

l Licease No.: SNM 1097 Repoit No.: 70 1113/97-06 l Licensen: General Electric Company Facility: Nuclear Energy Production Location: Wilmington, North Carolina Dates: June 2127,1997 Inspectors:

G. Troup, Sr. Fuel Facilities inspactor, Region ll D. Ayres, Fuel Facilities inspector, Region ll J. Davis, Criticality Safety inspector, Fuel Cycle Operations Branch (FCOB)

G. Humphrey, Resident inspector, Region ll L. Lessler, Sr. Operations Research Analyst, FCOB J. Olencz, Chemical Safety inspector, FCOB G. Smith, Chemical Safety inspector, FCOB J. Wang, Sr. Health Physicist, FCOB Accompanying Personnel: E. McAlpine, Chief, Fuel Facilities Branch, Region il P. Ting, Chief, Operations Branch, NMSS Approved by: E. J. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety Enclosure 9700210235 970011 PDR ADOCK 07001113 C pm 1

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FXECUTIVE

SUMMARY

General Electric Nuclear Energy Production NRC Inspection Report 701113/97 06 This special, announced inspection was focused on the status of the Dry Conversion Facility (DCF), including completion of construction, nuclear criticality safety, chemical safety, radiation protection and testing of systems associated with the DCF.

Within the scope of the inspection, no violations were identified. Three inspector follow.

- up items (IFis) wore reviewed and closed.

Drv Conversion Facility Construction e

Repairs to the roof had been completed and the roof installation was adequate for an Moderation Restriction Area.

The integration transfer corridor had been installed in accordance with the design and the proposed administrative controls were adequate. The use of the corridor was approved in accordance with the license and administrative requirements.

Nuclear Criticality Safety e Nuclear safety analyses reviewed appeared technically adequate and were based on consideration of credible process upsets.

• Appropriate controls and limits were established to prevent an inadvertent criticality, e There was reasonable assurance that the nuclear criticality safety evaluation requirements for operations, maintenance, and surveillance, would be communicated successfully to the operations and maintenance staff, and implemented properly, e The location and spacing of the Criticality Warning System detectors and horns met 10 CFR 70.24(a)(1) requirements and were adequate to ensure safe operation of the DCF.

Chemical Safety e The chemical safety program appeared adequate to address the most significant chemical hazards associated with the DCF. In general, good engineering design had incorporated safety into the Dry Conversion Process.

2 o The assumptions in the Integrated Safety Analysis appeared reasonable and provided an adequate safety envelope for operating the system. The Standard Operating Instruction for vaporization and HF operations adequately addressed chemical safety issues, the appropriate ISA safeguards, and were clearly written to provide adequate Instructions to operate the system.

Preventive maintenance and periodic test programs were in place for safety j interlocks and barriers.

The training provided for the DCF staff and emergency response personnel was extensive. The HF training was well thought out and seemed to cover all aspects '

of the HF equipment. The training provided good Information on the hazards l associated with HF use and the recovery actions needed in the event of an HF accident.

The licensee had procedures and equipment in place to adequately respond to an accident involving HF.

Radiation Protection e

The essential elements of the radiation protection programs for the DCF appeared to be complete nd had been implemented to process natural uranium under the Agreement State Material License.

The use of engineering controls in the design of the DCF was in conformance with the ALARA requirements of 10 CFR 20.1101(b). The licensee's radiation protection program and the use of engineering controls appeared adequate to ensure radiation safety for startup of the Dry Conversion Process up to 5%

enriched uranium, o The placement of Stationary Air Samplers and the support instrumentation needed to cosmt the air samples is adequate for the startup of the DCF to process 5% enriched uranium, o Calibration of the Criticality Warning System detectors is in conformance with plant procedures.

Pre-Onorational Teating No-load and start up tests were satisfactorily completed for the powder handling portions of process line 1.

• The functional tests for powder operations were performed and demonstrated proper operation of the Active Engineered Controls, o

Functional Test Instructions need to be revised to reflect lessons learned during initial testing.

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Process ConttnL8vstem

• The Process Control System had been Installed, validated and tested in accordance with approved administrative requirements.

e The software was under controls to ensure than only approved changes were made and appropriate records maintained.

Attachments Partial List of Persons contacted inspection Procedures Used List of items Opened, Closed and Discussed List of Acronyms - ,

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i REPORT DETAILS Summarv of Plant Status During the inspection period, fuel production and uranium recovery operations were conducted consistent with production uchedules. No process upsets or reportable events occurred.

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No other NRC inspections occurred during this period. '

The facility NRC license (SNM 1097) was renewed on June 27,1997, for a period of 10 years.

1. Drv Conversion Facility (DCF) Construction (880201

a. Roof Construction (1) In199etion Scoon The inspectors reviewed the status of the completion of the facility roof membrane.

(2) Observations and Findinas As noted in NRC Inspection Reports (irs) 70-1113/97-02 and 70-1113/97-04, the top (final) membrane of the facility roof required repairs to some areas and a final inspection and acceptance. The roof is an integral part of making the DCF a " moderation restriction area" (MRA).

An inspection was conducted by the roof supplier on April 4,1997.

The initial inspection gave the roof a rating of "8 out of 10." Several areas requiring repair were identified. The roof installer performed repairs to the identified areas that day. A final inspection by the roof supplier, the roof installer and the owner gave the roof a rating of"10." The roof supplier issued a final inspection report and signed the warranty certificate, indicating that the roof was completed as intended.

On June 24,1997, the inspectors toured the roof area and observed the repaired areas, accompanied by a representative of the facility owner. The inspectors observed areas which had been repaired, including those noted in IR 70-1113/97 04. The inspectors concluded that the roof installation was complete.

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2 (3) Conclusions The Inspectors determined that repairs to the roof had been completed and the roof installation was adequate for an MRA.

b. Integration Transfer Corridor (1) Inspastion Scope The inspectors reviewed the status of the integration transfer corridor.

(2) Observations and Findinas t

The Integration transfer corridot is a'section in the existing Fuel Manufacturing Operation (FMO) which has been modified to permit bulk powder containers to be moved from the powder preparation area in DCF to the pellet press stations in FMO. Initially, the concept was that a tunnel would be constructed so that all powder movement would be within an MRA. However, the area through which the corridor passes is already designated a " Moderation Controlled Area" or MCA. Consequently, there are rio sources of moderation which are not protected, such as shrouding process piping and directing floor drains away from the area. The design was changed to remove the tunnel but maintain a specifically designated area for the transfer.

The description of criticality controls for the corridor was submitted to the NRC on May 27,1997, as part of a response to a Request for Additionallnformation. The inspectors observed that an MRA had been constructed around the press stations and barriers had been installed to prevent the movement of the bulk transfer containers anywhere except down the corridor to the MRA, Containers cannot be moved out of the corridor and stored. Administrative controls will be used for the movement so that once a container leaves the DCF, it must be attended and moved directly to an MRA.

The findings of the Integrated Safety Analysis (ISA) for the portion of the Integration Process dealing with the transfer corridor and the proposed controls were presented to the Wilmington Safety Review Committee (WSRC). In accordance with Part I, Chapter 2, section 2.3.1. of the License Application and Practkes and Procedures (P/P) 401, "Wilmington Safety Review Committee," the WSRC must review new facilities or major changes to existing facilities. The transfer corridor was considered to be a " major change." At the meeting held on June 26,1997, the WSRC approved the transfer corridor and authorized the movement of bulk containers containing

3 natural uranium powder from the DCF to the pellet press stations.

i The other two major portions of Integration will be reviewed at a later date.

(3) Conclusient The inspectors determined that the integration transfer corridor had been Installed in accordance with the descripilon and that the proposed administrative controls were adequate. The use of the corridor was approved in accordance with the license and administrative requirements. 2

2. Huglear Criticality Safety (NCS) (88011)

a. NCS Evaluations (1) Insnection scone The inspectors reviewed the licensee's NCS analyses for the new Dry Conversion Process (DCP) to verify that: 1) the analyses were completed and reviewed by qualified personnel; 2) the analyses identified all credible accident scenarlos and established NCS limits for controlled parameters to prevent criticality; 3) the NCS controls established were available and reliable to support the safety function; and 4) the results meet license requirements. The analyses were selected based upon criticality risk potential and included the following:- (1) DCP Conversion Reactor Kiln; (2) DCP HF recovery and Storage; (3) Determination of Minimum Critical-Moderation for 5% UO,; and (4) JAERI Heterogeneous Effect Methodology.

(2) Observations and Finding 1 At the time of Inspection,14 of the 25 analyses suppoating the DCF wt.re completed; of those completed, five specifically addressed the operation and safety of DCP equipment and the remaining nine were general analyses supporting the engineering assumptions of the specific analyses. For those analyses reviewed, the methodology, results, and independent review appeared adequate to ensure safety of DCF. The analyses described credible accident conditions and provided reasonable and reliable controls to preclude such adverse effects.

Two additional topics were discussed with the licensee. These areas included: 1) CSA credible events, and bounding assumptions which can be better justified and cross-linked with ISA events; and

2) Specification of safety factors associated with process upset

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conditions could be supplemented with additional technical Justification as to the porsibility or rate of exceeding the 2

established safety limits. For Instance, a high pressure steam upset in the reactor kiln was not specified in the analysis even though this accident condition was initially considered in the ISA. Also, j consideration of safety factors identify when a condition would exceed a safe value, but did not Indicate if such conditions was l credible or the rate of change which must occur before the limiting 2

K.,, value was reached (see " Loss of Moderation Control" in

Reactor Kiln analysis). Although these issues did not effect the Immediate safety of the DCF operation, the licensee agreed to l evaluate these concerns and determine if such actions would

increase safety effectiveness.

i While several examples were noted whereby an CSA did not i rigorously consider /model obvious process upset conditions, l subsequent discussions with knowledgeable plant staff Indicated that appropriate consideration had been given to these conditions.

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J I (3) Conclusions

The analyses reviewed appeared technically adequate and were ,

based on consideration of credible process upsets. Appropriate  ;

controls and limits were established to prevent an inadvertent j criticality.

l b.- Operational Activities j (1) Inspection Scone i The inspectors reviewed the licensee's implementation of its

change control process with regard to the DCF to verify that

management functions (including establishment of written l procedures for operations, maintenance and surveillance; operator

training; and posting of limits) and plant activities were being l conducted as described in the requirements of the NCS evaluations i and the license.

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( (2) Observations and Findinas j

Well designed active engineering controls had been built into the new DCF system from the early design stage to control moderation as the single type of control utilized for the DCF. It appeared that these controls had been properly deployed and tested under actual l operating conditions using natural uranium as the working material, j Reliance upon operators for maintenance of NCS, hoviever, had not been entirely eliminated. A sampling of five nuclear criticality j- .

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5 evaluations for the DCF was examined and the Inspector determined that there were as many as 42 different controls of the "OPR" type that needed to be integrated into the operating procedures.

At the time of the inspection, none of the Nuclear Safety Release / Requirement (NSR/R) documents which the licensee would use to communicate control requirements to the operations staff had been completed relative to NCS requirements for the DCF, and none of the Safety Operating Instructions (Sols) or Operating Procedures (ops) fully reflected the NCS control requirements. it could not be verifled during the inspection, therefore, that the NCS .

control requirements contained in the CSAs had been consistently integrated into the DCF operating procedures.

During previous inspections, the licensee's configuration control program and change control program had been Inspected and found to be satisfactory. The licensee exhibited documentation during the ,

inspection indicating how the change control process would be implemented to ensure that the NCS control requirements would be adequately integrated into operating procedures for the DCF program. This process also provides for ensuring that the operators receive all training required by the CSAs and that all active engineered controls are in place and in operable condition (as verified by pre-operational functional testing) before operation commences. >

NSR/Rs relevant to each operating procedure are always referenced at the beginning of the procedure. In addition, Section Administrative Routine (SAR) 350-30, " Writing Operations Procedures", Rev. 2, dated April 11,1997, required operating instructions prescribed in an NSR/R to be integrated into operating procedures,"as appropriate," so that each of the NSR/R operator requirements appears in the procedure directly before the operational step where it is relevant or has to be performed. The presence of the NCS or other safety requirements in the operating procedures were required to be Indicated by standardized icons, both in written and electronic versions of approved operating procedures, implementation of this requirement could not be confirmed for NCS, since the NSR/Rs for NCS had not been completed for DCF The observation of the extent to which this '

requirement was being met for other safety requirements in NSR/Rs, or the extent to which NCS requirements in NSR/Rs had been Integrated into operating procedures for other facility systems, however, provided confidence that the process would be adequately executed for DCP when the NCS relevant NSR/Rs were completed.

An examination of a small sampling of other previously approved NSR/Rs and operating procedures showed that the reviewers in the

6 nuclear safety function exercised discretion in determining which NSR/R requirements should be integrated into the operating procedures, and where the appropriate icons should appear.

Other operating proceduras were examined to trace the flow down of radiation protection related NSR/Rs, with the finding that not all l .

auch NSRIR requirements specifically appear in the procedures with the appropriate icons. The licensee explained that certain radiation l

protection requirements that were common procedure throughout the plant would not need to be repeated in the operating procedures  !

for each instance in which they were required (e.g., wearing a face j mask when opening up a piece of equipment that could be contaminated).

The licensee's implemtr ntation of its configuration control program, as it pertains to the new DCF operation, containe calibration, surveillance, and preventive maintenance requirements at least annually for virtually all equipment rolled upon for safety.

Upon discussion with licensee representatives, it was determined that the annual requirement was an arbitrary specification, since there was not yet any significant operating experience for the new equipment that would permit different determinations to be made based on operating experience. Licensee representatives stated that the various calibration, surveillance, and preventive maintenance requirements for different safety equipment would likely be adjusted to reflect operating experience as it is accumulated. However, no licensee procedure was identified that directed them to make such adjustments. Harsh operating conditions or other causes could result in degradation of performance or loss of calibration of equipment rolled upon for safety earlier than one year. This could result in the quality of the active engineered criticality controls provided by the equipment being out of specifications during operation, possibly without the licensee being aware of such a condition. The licensee Indicated that during the initial phase of operations, there would be careful evaluations of system performance to ensure that the process equipment and engineered controls are functioning properly. This would include frequent sampling for moisture content of the powder product coming out of the reactor / kiln to verify that the moisture analyzer engineered control is functioning accurately, and according to specifications. Any difficulties in the quality of performance of the engineered controls would become evident during this procese, and adjustments in the frequencies of calibration, surveillance, and preventive maintenance activilles could be adjusted during this period. The inspectors were satisfied

7 that the licensee had an appropriate plan for determining any necessary adjustments of such frequencies.

(3) Conclusions There was reasonable assurance that the NCS evaluation requirements for operations, maintenance, and surveillance, would be communicated successfully to the operations and maintenance staff, and implemented properly.

c. Criticality Alarm Monitoring System (1) Insoection Scone The inspectors reviewed the Criticality Warning System (CWS) to determine the adequacy of system design, placement, and performance requirements in accordar)ce with the requirements of 10 CFR 70.24(a)(1).

(2) Observations and Findings The inspectors performed an area walk down and determined that the detectors were appropriately located and spaced to avoid significant shielding that would degrade' system performance, Supporting electronics for the detectors were located to minimize damage due to corrosive atmosphere, fire, etc.

Although the licensee did not perform sound pressure level tests as recommended by American National Standard ANSI 8.3," Criticality Accident Alarm System" to ensure that the alarms would be heard over typical ambient noise levels, the licensee did position personnel in all normally manned locations to ensure the CWS horns were audible. This action meets license requirements.

Audibility of the warning horns was part of the corrective actions being evaluated as the result of an Unusualincident Report (UIR) '

and was being tracked as Inspector Follow up item (IFI) 96-11-01.

(3) Conclusions The location and spacing of the CWS detectors and horns met 10 CFR 70.24 a,1 requirements and were adequate to ensure safe operation of the DCF, Although sound pressure measurements were not conducted as recommended by ANSI 8.3, adequate system performance was demonstrated by alternate means,

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d. NCS Emergency Response (1) inmatetion Scone The Inspectors examined the licensee's emergency response plan for fighting fires in the DCF areas to verify that excess moderator would not be Introduced for fire fighting purposes that would result in a nuclear criticality.

(2) QAservations and Findinas The DCF was classified as a Moderation Restriction Area. As such, there were no water lines, including fire protection systems, in the area. Fire fighting was accomplished using carbon dioxide (CO,)

extinguishers, which were located throughout the facility.

The CSAs for the storage of powder containers demonstrated that l the various storago an ays of containers were within the license '

requirements with full water reflection around the containers. In the extreme event that water would ever be introduced into the facility, ,

storage arrays would be safe. Integrity of each container was  !

assured by the mechanical closure on the container opening, which '

was required to be in place before container movement to storage.

(3) Conclusions There was sufficient margin of safety in the calculated values of K.,,

to tolerate the use of water for fire fighting in the specific area examined.

3. Chemical Safety (88056J1061. 88062. 88064

a. Process Safety Information (1) In#.pection Scope The inspectors reviewed the licensee's Chemical Safety practices for the new DCF to verify that (for the highest risk chemical hazards) the appropriate Process Safety Information (PSI) had been gathered and Incorporated into the ISA, and that the assumptions in the ISA were valid and provided adequate safety for the process.

(2) Observations and Findinas The inspectors reviewed the PSI documents. Specifically, Technical Reports (TRs) for Vaporization and Cold Trapping (TR 1331.00) and Hydrofluoric Acid Treatment (TR 1336.00) were reviewed. These 4

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documents contained detailed system overviews and process Information. Also, both technical reports detailed the process operations and controls that needed to safely operate the systems.

Next, the insoectors reviewed the appropriate operating procedures, i Based on these reviews, the inspectors noted that appropriate controls and limits were defined in the technical reports and Implemented in the appropriate operating procedure.

The ISA considered accident conditions that could lead to personnelInjury or release of the hazardous chemicals. Both the vaporization and HF recovery sections of the ISA utilized the HAZOP method to review the process. The inspectors verified a sampling of the controls rolled on for safety to ensure that they were in place and performed the function that the ISA assumed.

(3) Conclusions The chemical safety program appeared adequate to address the most significant chemical hazards associated with the DCF. In general, good engineering design has incorporated safety into the DCP process.

The assumptions in the ISA appeared reasonable and provided an adequate safety envelope for operating the system. The SOls for vaporization and HF operations adequately addressed chemical safety issues, the appropriate ISA safeguards, and were clearly written to provide adequate instructions to operate the system.

b. Maintenance and Inspection (1) Intoection Scoot The inspectors reviewed the controls relled on to ensure the safe operation of high risk chemical equipment and determine that a program exists to ensure that these controls will be available and reliable when needed in the future.

(2) Observations and Findinas The inspectors evaluated several safety controls and equipment designated in the ISA to determine if programs were in place to ensure that these controls would be available and reliable when needed. The licensee's maintenance program utilized a computer program to plan, schedule, track and maintain records for maintenance activities. The frequency and requirements for maintenance and/or functional testing were based on the results of the ISA. The inspectors reviewed several safety controls relied on

10 to prevent or mitigate an accident condition. Specifically, the inspectors reviewed detection and monitoring equipment, and system interlocks and barriers. In every case, appropriate preventative maintenance and/or functional test instructions were in i

place.

During a tour of the HF building, the inspectors noted two concerns associated with accident monitoring or mitigation equipment. The first was associated with the HF detection system. This system l provided continuous monitoring at four locations throughout the building. If the levels of HF exceed the alarm limit, the detector l would initiate an audible alarm in the DCF control room and a visible alarm outside of the HF building, but would not alert any l plant personnelinside the HF building. This concern was expressed to licensee personnel who, in turn, initiated a change request to provide an audible alarm to warn persons in the building.

Also, the inspectors noted that there were no preventative maintenance and/or functional test programs in place for the HF building's emergency scrubber system. This scrubber would be manually activated by plant personnelin the event of a significant HF leak in the building. The system would automatically shut off the building ventilation fans and redirect the ambient air through a water scrubber and out the emergency stack where it would be monitored for HF content. This system is vital to an HF spill emergency situation and rolles on several automated actions. The I

inspectors were concerned that no plans existed to test the functionality of this system. Licensee personnel agreed with these concerns and initiated a program to test the operation of the emergency scrubber system annually.

(3) Conclusions Preventive maintenance and periodic test program were in place for safety interlocks and barriers. The licensee took prompt and comprehensive action to address concerns raised by the inspectors concerning chemical safety issues.

c. Chemical Safety Training (1) Insnection Scone The inspectors reviewed the training program that the licensee had provided for the plant personnel to ensure that it was adequate to prepare them for the newly introduced chemical risks.

11 (2) Observations and Findinna HF in large quantitles is a new hazard for most plant personnel at the facility. Several training classes were set up to train operations personnel and emergency responders in all aspects of HF handling.

The licensee consulted experts from the HF Acid Industry to develop several training classes. These classes were taught to both operations personnel and emergency responders, and covered many aspects of HF use, safety and medicalissues. The scope of this training is discussed further in IR 701113/9744.

(3) Conclusions The training provided for the DCF staff and emergency response  ;

personnel was quite extensive. The HF training was well thought out and seemed to cover all aspects of the HF equipment. The ,

training provided very good information on the hazards associated with HF use and the recovery actions needed in the event of an HF

, accident.

d. Emergency Procedures f (1) Inanection Scone The inspectors reviewed the facility's emergency plan and implementing procedures to verify that new hazards had been adequately incorporated.

(2) Observations and Findingg The Radiological Contingency and Emergency Plan and implementing procedures have been modified to reflect the additional hazards introduced with the operation of the DCF. The inspectors' discussions with facility fire protection and emergency response personnel Indicated appropriate equipment and facilities were in place in the event of a hazardous material release or injury.

Additionally, the licensee had helped prepare the local hospital staff to adequately respond to an HF burn if the need ever occurs.

(3) Conclusions The licensee had procedures and equipment in place to adequately respond to an accident involving HF.

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4. Radiation Protest [gn (RPl(83822) I

a. RP Program (1) Insoection Scone l

The Inspectors conducted a review of the licensee's radiation protection program to determine whether it was adequate to ensure radiation safety for the DCP facility. The inspection included discussions with the Radiation Safety Engineering (RSE) and RP staff, independent review of the Radiation Safety Analysis (RSA) '

reports for the DCP facility, the resulting NSR/R requirements, and selected audit of pre-operational radiation protection checklist Itt ms for the DCF facility.

(2) Observations and Findinna Most of the radl60n safety programs were extension of existing programs of t;ie licensed facility. The licensee had been able to perform test runs of the DCF using natural uranium under the North Carolina Material License, in terms of radiation safety, DCF operation with natural uranium is not significantly different from operation with 5% enriched uranium. Therefore, the licensee's performance using natural uranium provided a strong indicator of the quality of its radiation safety program when operating with 5%

enriched uranium.

The ISAs were developed with the input of the facility's RSE staff as well as with other safety disciplines. The inspectors observed that the RSE staff had detall kno.vledge of various operating systems of the DCF, in part due to their involvement with the ISAs. In addition to the 18As, the RSE staff was able to provide input into the design of the DCF facility based on lessons learned from operations of the three other DCF facilities and frcm the licensee's own wet processing operational experience.

Discussions with the RSE staff Indicated that engineering controls were designed into the DCF facility in conformance with the As Low As is Reasonably Achievable (ALARA) requirement of 10 CFR 20,1101(b). During a walk through of the DCF, the inspectors observed that additional hoods (from the original design) had been added in the rooms containing the sifters (homogenization area) to minimize airborne uranium and radiation contaminations in these rooms. These rooms had been the most contaminated areas for the other similar DCFs due to inadequate designs for uranium confinement.

J 13 The inspectors performed an Independent review of nine RSAs for l - the DCP facility, which include the calculation for placement of the l CWS detectors. The Inspectors noted no technical deficiencies.

Since the ISAs had already addressed accidental releases of 4

' radioactive materials, the RSAs were confined mostly to the determination of NSR/Rs for normal operation of the DCF. Although the NSR/Rs in the RSAs were general, the inspectors noted that the

NSR/Rs for each subarea of the DCF were clearer and more specific.

s The inspectors observed that all draft NSR/Rs for each subarea of i

the DCF had been completed, i The inspectors reviewed selected items of the radiological pre. l l operational checklist for the startup of the DCF and found them to

! be completed. The inspectors nottd that several items were not to  !

i be completed until July 31,1997. The Inspectors noted that these Items were not required to ensure radiation safety for startup of the i DCF for 5% enriched uranium.

) (3) .Qnosiusions l The essential elements of the radiation protection program for the

! DCF appeared to be complete and had been implemented to I process natural uranium under the Agreement State Material License, s The use of engineering controls in the design of the DCF was in l conformance with the ALARA requirement of 10 CFR 20.1101(b).

2 The licensee's radiation protection program and the use of l engineering controls appeared adequate to ensure radiation safety j- for startup of the DCP processing up to 5% enriched uranium,

b. RP Procedures (1) Inspection Scone 4

j_ To ensure the NSR/Rs had been incorporated into DCF operating procedures, randomly selected procedures were selected for review.

l (2) Observations and Findinas

In order to process natural uranium through the DCF, operating j procedures should be in place which incorporate the NSR/Rs. The inspectors audited a selected number of operating procedures and observed that the NSR/Rs were specified in the front part of each operating procedure which could be obtained directly from l computer terminals placed in the DCF. However, not all NSR/Rs

14 i were incorporated into the body of the operating procedures which was at the discretion of the Operations staff who wrote the procedure and the RSE staff who approved the procedure. The inspectors also observed that a number of Practices and Procedures (P/Ps) and Nuclear Safety Instructions (NSis) applicable to radiation protection for the DCF had been revised by April 7,

! . 1997.

(3) Conclusions L

The plant's DCF operating procedures and radiation protection procedures for processing of natural uranium were adequate to ensure radiation safety,

c. Instruments and Equipment (1) Inspection Scope The inspectors toured the DCF and the Radiation Protection Counting Rooms to determine whether all necessary instruments and equipment had been Installed and were operable for monitoring of radiation resulting from DCF operations.

(2) Qbservations and Findinas Besides engineering controls designed into the facility to confine the uranium, stationary air samplers (SASS) had been placed through out the facility at locations where there was the possibility of a break in confinement. The inspectors observed that the number of SASS appeared to be sufficient to properly characterize the airborne activity in the DCP facility. The inspectors further observed that the airflow of the SASS were within the specification for these type of instruments and that the earlier problem with inadequate airflow have been corrected by the RSE staff. Future adjustment of the placement of SASS is discussed in the next section, " Exposure Controls."

The Inspectors conducted a walk through of the Radiation Protection Counting Rooms. The inspectors observed that the number of automatic counting systems appeared to be adequate to ensure that all air sample results would be completed in a timely manner, and these counters were 9roperly calibrated. The -

Inspectors also observed that the automatic counting system for envlronmental samples were placed in the same counting room, thus increasing the potential for cross contamination from samples collected for processing operations. The radiation protection staff,

15 however, indicated that this had not been a problem for results from environmental air monitors.

The inspectors also reviewed the calibration procedure for CWS detectors. The CWS detector (Eberline DAl 6c cc) indicator light was checked on a daily basis. On a monthly basis, the detector was checked with its internal calibration source. Each detector was also checked with an external source at its location on an annual basis.

A review of the calibration records indicated that the 12 CWS detectors in the DCF had been operating since April,1997.

(3) Conclusions The placement of SASS and the support Instrumentation needed to count the air samples was adequate for the startup of the DCF to process 5% enriched uranium.- Calibration of the CWS detectors was in conformance with plant procedures.

d. Exposure Controls (1) Insnection Scone The Inspectors reviewed the bloassay and air-sampling program for the DCF to determine the adequacy of these programs for exposure controls.

(2) Observations and Findinas Based on the operating experiences at similar facilities, the primary radiological hazards at the DCF should be due to inhalation of airborne uranium. External radiation exposure at the plant should be significant only in areas the near empty UF. containers containing heels.

10 CFR 20.1204 authorized the licensee to utilize several methods to assess intakes of uranium. The licensee had chosen to use urine ar#ysis for DCF areas that contains soluble uranium, and rely on results of the SASS and worker stay times to assess intakes of insoluble uranium. The inspectors observed that the methods chosen were appropriate based on the current detection capabilities for uranium. As part of its pre-operational check list, the licensee planed to use smoke tests and lapel air samplers on selected workers to determine data on air flow patterns and air sampling representativeness no later than July 31,1997. Based on these results, the locations of the current SASS may changed. The SASS will be calibrated in accordance with Regulatory Guide 8.25,

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" Calibration and Error Limits of Air Sampling Instruments for Total Volume of Air Sampled."

While touring the DCF, the inspectors observed that all activities which may result in release of uranium powder to air were limited to the first and third floors of the facility. In addition to engineering !

design, the inspectors observed that the NSR/Rs appropriately required the use of full face masks for operations such as breaking containment of process equipment (e.g., NSR/R # 15.03.06 In the slfter room).

1 (3) Conclusions The licensee's exposure control program was adequate to ensure radiation safety for_the workers at the DCF. The principal open item was to establish the adequacy of the SAS locations.

e. Surveys (1) Insnection Scope The Inspectors reviewed the licensee's survey program for the DCF to determine the adequacy of this program to ensure contamination and exposure control.

(2) Observations and Findinga The inspectors reviewed the SAS results for the DCF when natural uranium was processed. The air sampler filters were replaced every eight hours and a quick count was performed by the RP technician using a portable survey meter. Higher than normal air sample results could usually be detected visually or with the portable survey meter and were confirmed by counting on the automatic planchet counting system. This information was promptly provided to the Operations staff for corrective actions.

Besides dally morning meeting with the Operations staff, RP issued a weekly summary report for distribution to all affected parties. The inspectors noted that the weekly summary report for June 9,1997 to June 15,1997, stated that RP had noted discolored filters at Line 1 powder outlet. Operators found the cause of this higher than normal SAS result to be due to powder composite sample bottle screwed on at an angle (i.e, not seated properly) which resulted in powder escaping around the seal during the nitrogen purge. The inspectors observed that daily meetings and weekly summary reports were useful vehicles to bring RP survey results to the attention of the Operations staff for corrective actions.

1 17 (3) Genclusions RP survey results were promptly brought to the attention of the Operations staff for possible corrective actions. Review of selected RP survey results and weekly summary reports indicated that Operations staff had made all appropriate corrective actions to ensure contamination and exposure control.

6. Pre Ooerational Testina (88020. 88025)

! a. Pre Operational Tests 1

(1) Inspection Scope l The inspectors reviewed the completion of the system pre-L operational tests to verify that equipment check-outs had been completed.

(2) Observations and Findinas The equipment contractor developed two sets of procedures for initial system 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 motors, checks on equipment, verification and adjustment of valve movement, and threshold measurements of interlock and alarm devices.

The no load test for the homogenizer was conducted on May 8, 1997. Following changes to the software to include graphics, the no load test was conducted again on May 16,1997. The no load tests for the blender system was completed on May 15,1997. Both sets of tests were satisfactorily completed. The inspectors reviewed the test records and had no questions.

Start up tests for the powder systems consisted of system leak tests of the systems and setting of gas pressures and flow rates.

Start up tests were conducted using the vendor's " Start-up Manual,"

which issued by the licensee as a Temporary Operating instruction (TOI). Start up tests were completed prior to conducting the Functional Tests in May.

(3) Conclusions No-load and start up tests were satisfactorily completed for the

- powder handling portions of process line 1.

18

b. Functional Tests (1) Insoection scone The inspectors reviewed the completion of the functional test instructions (FTis) for devices and controls designated Active Engineered Controls (AECs).

(2) Observations and Findings As discussed in IR 701113/97-02, Paragraph 5, an ISA had been performed for the DCF. As a result, a nuinber of AECs were  ;

identified. The licensee's Internal procedures required that AECs which were NCS controls had to be periodically tested in accordance with approved FTis.

The FTis for AECs on process line i for vaporization through powder outline and for the HF facility were previously reviewed.

This was documented in IR 701113/97-04, Paragraph 3.b.

} The inspectors reviewed the completion of the FTis for powder

homogenization through blending for process line 1 in DCF. In

these portions of the system, process parameters were controllad by Programmable Logic Controllers (PLCs) which Interfaced with the Fuel Business System (FBS) computer system and/or the Manufacturing Information and Control System (MICS) computer system, rather than the Distributed Control System (DCS) used for vaporization through powder outlet. In these cases, operational parameters had to satisfy pre programmed conditions, such as maximum powder weight or amount of additives introduced *o the powder, or the operation would be shut down.

The FTis for the homogenization operation (2 tests) were conducted on May 16. Following one test, it was recommended that an interlock be modified to better control operations. The interlock was modified and retested on June 4.

The FTis for the blending / pre-compaction / granulation stages (12 tests) were satisfactorily conducted on June 2,1997. The inspectors reviewed the test results on June 23 and verified that the tests were satisfactorily completed and that Nuclear Safety had accepted the results.

The inspectors noted that all of the completed FTis had changes-(some substantial) made In the field, as allowed by the administrative procedure. These FTis will be_used for the testing of other process lines as well as for the periodically (annual or after k

-, . ~ - - - - . . . - - - , , . , - - - . - - , , - - - . ~- ..u,--nn,--. -- , -- n ,-,,,,< , , - . - , - , , , , , - , , - + , vn ,n--..--,, -n - r ----

19 maintenance) required tests. Licensee representatives stated that the FTis would be revised to reflect the field changes and any other isssons learned during start up operations.

(3) Gonclusions The functional tests for powder operations were performed and l demonstrated proper operation of the AECs. FTis need to be revised to reflect lessons learned during initial testing. l

6. Operatloas (88010. 88020)

a. Operator Training (1) Inspection Scont The inspectors reviewed the status of the qualification program for operators to determine if the operators were ready to operate the DCF with NRC licensed material.

(2) Dattrations and Findinnt As documented in IR 701113/97-02, Paragraph 2, the operating staff had completed the classroom training associated with operation of the DCF, and had started working on completion of the qualification cards. Initially, pre-qualification cards were used in the absence of system start up and the introduction of uranium. Now, qualification cards are being completed.

The inspectors reviewed the electronics document form of the qualification cards for randomly selected operators on all shifts.

The inspectors noted that some operators had completed only a few of the qualification stages while others were complete or lacked only sign-offs in powder operations.

A licensee representative identified the Individuals with limited sign-offs as mainly maintenance personnel or persons who had joined the operations staff late in the staffing process. Maintenance personnel on each shift could perform operations but their primary duties were related to maintenance and testing.

The inspectors reviewed the qualifications for persons identified as operators. On each shift, there were multiple operators quallfled for the various operations in both the Control Room and on the process floor.

20 (3) Conclusions While final qualification were still in progress for some personnel, there were a sufficient number of qualified operators on each shift to operate the systems.

1

, b. Operating Procedure Implementation '

(1) Inspection Snape The inspectors selected a Sol and reviewed it implementation with system operators.

l (2) Qhaggyations and Findinas The inspectors reviewed Sol 1331, Vaporization, June 19,1997 revision, and discussed it with three operators. The inspectors noted that the procedure was written so that each step was specific for the required action and a minimum of actions, normally one action, was specified in each step. The Inspectors were able to understand the process and work through the operation even though they had never seen the procedure before.

The operators stated that this format was very easy for the operators because they could do a specific task or action and sign-off the step rather than having to multiple actions. With the electronic documents it is much easier to work through a sequence with this format.

The operators stated that as problems were encountered during the process start-up and testing, the activity was stopped until the necessary changes were made. The operators were knowledgeable in the requirement for verbatim compliance with the procedure.

They also stated that management was supportive to operator concerns and to maintain the quality of the procedures.

(3) Conclusions The format of the electronic procedures is easy for operators to follow and simpilfles the required actions for sign-offs.

21

c. Operating Procedure Changes l (1) Inspection Scapa The inspectors reviewed changes made to Sols to verify that changes were consistent with regulatory requirements and administrative requirements.  ;

(2) Observations and FindlDER The inspectors reviewed ten changes made to Sols during May, 1997. Several of these changes were administrative in nature and '

only required approval by a Quallfled Reviewer and the Area Manager in accordance with P/P 10-09, " Operating Procedures (ops) - FMO."

Other changes reflected either ISA or Readiness Review findings.

These changes required the approval of various safety functions.

The change approvsl sheets were on file in the Configuration  :

Management Center (CMC) and indicated approvals as required by r the P/P.

The inspectors also reviewed previous changes made to SOls which resolved identified problems or reflected lessons learned during testing. The inspectors determined that these changes were properly reviewed and approved and that the changes did not decrease the safety of the system. i (3) Conclusions Changes to operating procedures were properly reviewed and ,

approved. Changes were consistent with safe operations.

7. erd &tas Control System (88020)

(a) Inspection Scone t

The inspectors reviewed records to determine that administrative controls for process control computer systems for the DCF process line 1 had been a established and approved in accordance with administrative controls.

(b) Observations and Findinas P/P 12015, " Process Control System Management," Rev. 2, dated August 30,1996, describes the guidelines for_ the development, Installation, and maintenance of process control systems (DCS and PLCs) within the

22 ,

i FMO complex. In addition, PlP 120 5 lists the approved software engineers! technicians who are authorized to access the software or hardware to make changes. A Mandatory Modification to P/P 12015 was

' Issued on June 9,1997, which extended the applicability of the P/P to systems in the DCF and designated software engineersitechnicians for the DCF systems, it also designated the System Manager for the DCS in DCF and removed sogne previously approved software engineers from current  ;

access.

As part of the control system quellfication and testing, functional testing of AECs must be accomplished and operability of the system demonstrated. l Testing of the systems controlled by the DCS was documented in IR 70 1113/97-04 as well as Paragraph 4.b of this report. Once the system was ,

baselined, the software was placed under configuration control. '

The inspectors reviewed the Master Software Set (MSS), which was the official master copy of the software and supporting documentation, for process line 1 and the HF systems. The inspectors determined that the necessary documentation had been compiled and was stored in accordance with the P/P requirements.

The inspectors reviewed six changes which had been made to the MSS.

Each change was documented on a Software Modification Plan, which was approved by the System owner, System Manager and Nuclear Safety prior to implementation. Following completion of the modifications, the MSS was updated and signed by the software engineer.

(c) Conclusions The Process Control had been Installed, validated and tested in accordance with approved administrative requirements. The software was under controls to ensure than only approved changes were made and appropriate records maintained.

8. Erevious inanection Findings (9270,1}

a. (Closed) IFl 97-04 01, Corrective Actions Following Fire in Gadolinia Furnaco (1)_ Inanection Scone The inspectors reviewed the adequacy of the licensee's evaluation and proposed corrective actions for the gadollhia furnace fire that occurred on April 19,1997.

L ,

f 23 i

j (2) Observations and Findinas 9

1 i The inspectors reviewed the licensee's UlR and Root Cause  ;

i Analysis (RCA) of the event. The inspectors also reviewed l l Operating Procedure (OP) No. 70A1, Rev. 3, " Gad Shop Harper  ;

j Sintering Furnace" to obtain a better understanding of the event

description, the operational methodology of the furnace, and the I

reasoning of the proposed corrective actions. The insp6ctors found i

some apparent inconsistencies between the UlR and RCA, and between the event description In the RCA and the normal operating i sequence in the furnace procedure. The inspectors met with the i senior area engineer at the event site to receive a detailed l- explanation of the operation of the furnace and the sequence of .

l events leading to the fire. The engineer's explanation clarified the l event sequence such that the inspectors found the operator's l response to the event was within procedural instructions.

i The inspectors also found conflicting information within the RCA

itself. The event description in the RCA stated that problems with l_ the furnace purge timer during the shift prior to the event was noted i In the shift log. However, one of the causal factors listed in the RCA l Is that the problem with the purge timer was not noted in the shift

log nor at shift turnover. The inspectors confirmed that the problem j with the purge timer was, in fact, noted in the shift log. This l Indicated a problem with communicating the shift log information j with the onconiing shift operator. -

i The inspectors reviewed the seven corrective actions proposed in

the RCA and determined that, when fully implemented, they would

be adequate to preclude the same event from recurring. At the time i of this inspection, two of the corrective actions needed were in still

! progress. The review of the incident with all furnace operators had i not been completed on one shift, and the replacement / relocation of the gas flowmeter had net been completed. These two items were i

!_- to be completed prior to restarting the affected furnace.

l In addition to the corrective actions proposed in the RCA, the 1 Inspectors identified two other weaknesses which should be '

j addressed for the overall Improvement in the safety of the Gad j ,

Furnace operation. First, the transfer of information between ,

!- operating shifts via the shift log lacks formality; there was no i

mechanism whereby the oncoming shift acknowledges the log

entries of the previous shift (s) have been read and understood.

1 Second, the Gad Furnace operating procedure allows operators to I run the furnace in " manual" or " automatic", but the procedure does not provide any criteria or guidance as to when manual operation

was appropriate or sarranted. At present, the amount of manual l

b i

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a l

24 operation that occurs was dependent on the experience level of the operator, leading to a less consistent method of operation between shifts.

The inspector's conclusions were discussed with the cognizant Product Line Manager, who agre;J to review the OP and make changes accordingly.

(3) Conclusions l

The licensee's RCA and associated corrective actions were adequate to preclude recurrence of the event. An improvement in communications between shifts and within the operating procedure would reduce the uncertainty of equipment status upon shift change. The commitmen't to the corrective actions prior to furnace restart are such that IFl 97 04-01 la closed,

b. (Closed) IFl 97-04-02, Hydrolysis Tank Leak (1) Inspection Scone

The inspectors revhwed the adequacy of the licensee's evaluation and proposed corrective actions following a leak in a chemical process tank on May 5,1997.

(2)- Observations and Conclusions I

The inspectors reviewed the licensee's UIR for the erosion of the line #1 hydrolysis receiver tank wall which resulted in a small release of UF, gas arid uranyl fluoride solution. -The insi:ectors observed the hydrolysis receiver tanks in the ADU facility and discussed the incident and corrective actions with the area engineer and a process operator. The corrective actions taken included replacing the tanks on three of the four process lines with on-hand spares, reinforcing the wall of the remaining tank, and installing dip tube centering devices to minimize erosional effects on the tank walls.

(3) Conclusions The licensee'r analysis of the incident and corrective actions taken were adequate to prevent recuirence. IFl 97-04 02 is closed.

Y

25

c. _ (Closed)IFl 97-04-03, Control of Electronics Documents to Assure Approval Prior to Use (1) Inspection Scone The inspectors reviewed the licensee's action to assure that paper

("hard") copies of electronics documents which must be used are the current revision.

(2) Observations and Findinos Although operating procedures used in DCF were in electronics form, certain documents must be used in paper form ("ht.rd cori:s"), either to provide a copy to follow a sample or to provide a copy suitable for retention as a permanent record. The issue was how to assure that the paper copy provided was, in fact, the current revision of the procedure or form.

A mandatory modnication was issued to P/P 10-10, " Configuration Management," Rei. 2, on May 30,1997, to require that process for validating the authenticity of approved documents when a paper copy of an electronic document is used to record information.

For DCF documents, a triangular symbol was added to each record sheet or document which is routinely required to be in paper form.

The individual who prints the document has to sign or initial the symbol and date it, indicating that the copy came from the current directory. Individual sheets which routinely have to be used in paper form, such as sample travelers or tog sheets, were removed from the procedures and issued as separate documents so revisions could be controlled. All DCF FTis were revised and issued on June 4,1997, to include the symbol. A total of.M log sheets and forms were also revised to include the symbol.

The inspectors verified that various FTis and log sheets had been revised to incorporate the symbol and that the documentation of the approval was on file in the CMC.

(3) Conclusions A satisfactory method of assuring that paper copies of electronic documents are the current revision has been established. IFl 97 03 is closed.

26 9.- Exit interview (88020)

During the course of the inspecuen, daily meetings were held with the cognizant managers to discuss issues which had been identified and items which required additionalinformation. On June 27,1997, the inspection scope and findings were summarized with licensee representatives. The team leader discussed in detail l

the areas inspected, the findings and concerns which had been identified. There l were no dissenting comments expressed by licensee representatives. Although i l' proprietary documents and processes were reviewed during the scope of the Inspection, the proprietary nature of the documents or processes had been deleted from this report.

ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED 2

4 Licensee Personnel D. Barbour, Team Leader, Radiation Protection

• D. Brown, Team Leader, Environmental Programs

• D. Dowker, Acting Manager, Powder Product Line

• T. Flaherty, Manager, DCP Operations

• R. Foleck, Sr. Licensing Specialist

• N. Gutermuth, Manager, Industrial Safety R. Keenan, Manager, Site Security & Emergency Preparedness A. Mabry, Program Manager, Radiological Safety R. Martyn, Manager, Material Control and Accountability

• C, Monetta, Manager, GE-NE Environment, Health & Safety (EH&S)

• M. Moser, Acting Manager, Powder Production R. Mciver, Manager, DCP Facility Construction

• W. Ogden, Manager, Facilities (Acting Managec- Nuclear Energy Production on 6/27/97)

R. Pace, Manager, Logistics

'L. Paulson, Manager, Nuclear Safety

• L. Quintana, Manager, Fabrication Product Line

• R. Reda, Manager, Fuels and Facility Licensing

• H. Strickler, Manager, Site EH&S

• C. Tarrer, Team Leader, Configuration Management

• C, Vaughan, Project Manager, EH&S- New Facility Licensing / Safety

• Attended exit meeting on June 27,1997.

INSPECTION PROCEDURES USED IP 83822 Radiation Protection IP 88005 Management Organization and Control IP 88010 Operator Training / Retraining IP 88015 Criticality Safety IP 88020 Operations Review IP 88025 Maintenance / Surveillance Testing IP 88056 Process Safety Information IP 88061 Chemical Safety Training IP 88062 Maintenance and Inspection IP 88064 Emergency Response Procedures IP 92701 Follow-up on Inspector Problems

s 4 -

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

! Opened None Gleted IFl 97-04-01 Cortsctiv6 Act!ons Following Fire in Gadolinia Furnace IFl 97-04 Corrective Actions Following Leak in Hydrolysis Tank IFl 97-04-03 Control of Electronics Documents to Assure Approval Prior to Use Discussed IFl 96 11-01 Follow-up on long term corrective actions for CWS horns LIST OF ACRONYMS AEC Active Engineered Control CFR Code of Federal Regulations CMC Configuration Management Center CWS Criticality Warning System DCF Dry Conversion Facility

.DCP Dry Conversion Process FBS Fuel Business System FMO Fuel Manufacturing Operation FTl Functional Test instruction GE-NE General Electric- Nuclear Energy GE-NEP General Electric- Nuclear Energy Production HF Hydrogen Fluoride 9.t Hydrofluoric Acid IFl inspector Follow-up item IR _ inspection Report ISA Integrated Safety Analysis KGS Kilograms MCA Moderation Controlled Area MC&A Material Control & Accountability MICS Manufacturing information and Control System MRA Moderation Restriction Area MSS Master Software Set NCS Nuclear Criticality Safety NRC Nuclear Regulatory Commission NSR/R Nuclear Safety Release / Requirement OP Operating Procedure PLC Programmable Logic Controller

3 P/P Practices & Procedures RCA Root Cause Analysis RP Radiation Protection RSA Radiological Safety Analysis RSE Radiatlon Safety Engineering SAR Section Administrative Routine SAS Stationary Air Sampler SNM Spe:lal Nuclear Material SOI- Standing Operating Instruction TOl Temporary Operating Instruction TR Technical Report UF, Uranium Hexafluoride UIR Unusualincident Report UO, Uranium Dioxide-WSRC Wilmington Safety Review Committee 1

_ . . _ , . . _, ._. ,_, ..