ML20148E310

Insp Rept 70-1151/88-02 on 880222-26.No Violations & Deviations Noted.Major Areas Inspected:Mgt Controls, Training,Nuclear Criticality Safety,Operations Review & Previously Identifeid Items.One Unresolved Item Identified

ML20148E310
Person / Time
Site:	Westinghouse
Issue date:	03/16/1988
From:	Mcalpine E, Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20148E308	List: ML20148E305 ML20148E310
References
70-1151-88-02, 70-1151-88-2, NUDOCS 8803250061
Download: ML20148E310 (9)

Text

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P E800 UNITED STATES

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Report No.: 70-1151/88-02 Licensee: Westinghouse Electric Corporation Commercial Nuclear Fuel Division Columbia, SC 29250 Docket No.: 70-1151 License No.: SNM-1107 Facility: Commercial Nuclear Fuel Plant Inspection Conducted: F bruary 22-26, 1988 M

Inspector: /4 8T G. L. rcit#i,' tiel Facflities Pro Inspe: tor Date Signed Approved ^

By: [ N1 L h [ [f[

~ E. J.' NcAlpine, Chief ' /Da te 'Si g ned Material Control and Accountability Section Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection involved management controls, training, nuclear criticality safety, operations review, and previously identified violations and followup items.

Results: Within the scope of the inspection, no violations or deviations were identified. One Unresolved Item was identified regarding followup actions on previous NRC and licensee identified violations.

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8803250061 880316 PDR ADOCK 07001151 i C DCD

2 REPORT DETAILS

1. Persons Contacted

• E. P. Loch, Plant Manager

• E. E. Keelen, Manager, Manufacturing

• W. L. Goodwin, Manager, Regulatory Affairs

• J. Hubich, Manager, Chemical Manufacturing

• E. K. Reitler, Jr. , Manager, Radiological and Environmental Engineering J. W. Heath, Jr. , Manager, Health Physics Operations

• R. D. Montgomery, Sr. R&E Engineer

• J. S. Baker, Sr. R&E Engineer J. B. Hooper, Safety Engineer 1 R. D. Young, Maintenance and Technical Support Supervisor ,

B. D. Lewis, Conversion and Scrap Reprocessing Supervisor M. R. Spinnato, IFBA Supervisor ,

The inspector also interviewed several other licensee and contractor  !

employees. ,

"Attended exit interview.

2. Exit Interview The inspection scope and findings were summarized on February 26, 1988, with those persons indicated in paragraph 1 above. With respect to the previously identified violation (87-10-01) and the findings from the licensee's internal audits regarding nuclear criticality safety, the e inspector identified the corrective actions to prevent recurrence collectively as an Unresolved Item *. This action was acknowledged by ,

licensee management. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during the inspection. No dissenting comments were received from the licensee.

3. Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation 87-10-01, Failure to Handle Material in Accordance with Nuclear Criticality Safety Limits.

During an inspection on June 17, 1987, the inspector observed licensed

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material stored in arrays which were not authorized by the nuclear i criticality safety postings. In response to this violation, the licensee  !

committed by letter dated July 31, 1987, to make certain physical l modifications to prevent the specific violation and increase attention to

nuclear criticality safety requirements during audits and inspections.

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' Unresolved itees are matters about which more information is required to ,

determine whether they are acceptable or may involve violations or deviation.

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3 The inspector verified by observation during tours, discussions with management personnel, and review of audit reports and inspection checklists that the corrective actions specified - in the licensee's response had been completed.

The long-term corrective actions included the use of engineered (physical) controls and the minimization of administrative controls. The final actions this program are incomplete.

This violation is cloced for record purposes and the long-term actions are included in Unresolved Item 88-02-01, which is discussed in paragraph 7.

4. Management Organization and Controls (88005)

a. Organizational Structure The inspector reviewed the f acility organizational structure and compared it with Section 3 of the license application. No changes in the safety management organization have been made.

One organizational change had been made in that the Plant Applications Group has been incorporated in the Technical Services Group, Neithe> of these groups is directly responsible for implementing the safety program.

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No violations or deviations were identified.

b. Safety Committees The Regulatory Compliance Committee (RCC) performs the function of the Safety Committee The RCC was appointed by letter from the Plant Manager, dated July 8,1987, and the RCC charter was reissued at the same time. The inspector reviewed the minutes of the committee meetir.gs since July 1987, and determined that the meetings were held at (or exceeding) the required frequency with the required membership present. The inspector also determined that the agenda for items reviewed were in accordance with the charter.

No violations or deviations were identified.

5. 10 CFR 21 Implementation (36100, 88005)

a. The inspector verified that procedures have been established to cover identification and reporting of safety hazards and significant deficiencies. The applicable procedures are the Nuclear Fuel Division Policy and Procedure P-710, "Identification and Reporting of Substantial Safety Hazards, Significant Deficiencies and Unreviewed Safety Questions," and P-710-1, "Identification and Reporting of Substantial Safety Hazards (10 CFR 21) Relative to NFO Licensed Activities."

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b. The Manager, Radiological and Environmental Engineering has been designated as the "responsible official" for 10 CFR 21 matters. The Regulatory Compliance Committee is responsible for reviewing any identified potentially reportable items, and determining reportability. Such reports would require the review and approval of the RCC. The inspector discussed the review activities with the responsible individual and was informed that no items had been identified in 1986 or 1987 which required review under 10 CFR 21.

c. During tours of plant areas, the inspector observed that the postings as required by 10 CFR 21.6 were displayed in prominent locations.

No violations or deviations were identified.'

6. Nuclear Criticality Safety (88015)

a. Facility Changes and Modifications The inspector examined six nuclear criticality safety review requests and the associated analyses. The inspector verified that approved evaluation methods were used and that the calculations and analyses were checked by a second individuai. The inspector also verified that the analyses included a post-installation review and sign-off authorizing the use of the equipment.

No violations or deviations were identified,

b. Nuclear Safety Analyses The inspector discussed the methods used to perform nuclear safety calculations with the cognizant individuals and verified that the methods used were in accordance with the license requirements. The inspector also discussed the activities presently in progress which will provide the facility staff with the capability to perform nuclear safety calculations using the KENO codes. Activities which will be required include, but are not limited to, completing procedures, training and qualification of analysts and reviewers and benchmarking the codes.

No violations or deviations were identified.

c. Criticality Monitoring System 4

The inspector reviewed the new computer based criticality monitoring system and discussed the various alarms and associated actions with

two security guards. The inspector also determined that system is

covered by a procedure (RA-304, Rev. 0), and has been calibrated in accordance with procedure and license requirements.

No violations or deviations were identified.

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d. SNM Containers Boron glass Raschig rings are used in certain liquid tanks as a secondary criticality control method. The license requires that the rings and tanks be checked annually for settling, minimum volume and B203 content. The inspector reviewed the records for the settling, minimum volume determinations and B203 content made in 1987. All values met or exceeded the license requirements.

The licensee has added a different SNM shipping container for use.

The inspector verified that the container has a valid Certificate of Compliance and that the licensee has been registered as an authorized user.

No violations or deviations were identified.

7. Audits (88005, 88015, 88020)

a. The inspector reviewed the monthly criticality audit reports for the period of July-December 1987, and verified that the audits were conducted at the required frequency and in accordance with a plan, as required by the license. The reports identified problems to be rectified, the responsible individuals, and an action date.

Correction of identified items and the close-out date were documented. The adequacy of corrective actions was also reviewed and documented in subsequent licensee audits.

The inspector noted that several audit findings (licensee identified violations) during the period involved failure to adhere to nuclear criticality safety postings, with spacing between units in transit conditions being the predominant problem.

b. The inspector observed during tours that some action has started to provide physical controls in lieu of administrative controls. Such actions have included the installation of bumpers to maintain minimum separation between fixed units and carts, and increased use of fixed storage racks. Licensee management representatives informed the inspector that these actions were part of the long-term corrective actions for violation 87-10-01 and would also be the corrective actions for the licensee identified violations specified in paragraph a above.

c. The inspector informed licensee management that the audit findings would be treated as licensee identified violations under the provisions of 10 CFR Part 2, Appendix C. As the long-term actions are still pending for the previous violation, the issue will be tracked as Unresolved Item 88-02-01, until the ac; ions are fully identified and action taken. If the long-term corrective actions are adequate, the issue will be closed. If the long term corrective actions are not adequate, the violations will not be treated as licensae identified and a Notice of Violation will be subsequently issued.

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d. Licensee management representatives acknowledged this and stated that the plan would be identified and established by June 30, 1988.

8. Operations Review (88020)

a. Safety Systems The inspector verified that the following safety systems or devices were provided and had been tested or calibrated in accordance with the license requirements.

(1) Remote closing devices for UF6 cylinder valves when the cylinders are in the vaporizers (2) UF6 detection system on the steam condensate lines (3) Liquid level detectors on steam type UF6 vaporizers, and (4) Leak testing of UF6 cylinder-to-conversion connections (5) Additionally, the licensee has included a verification and sign-off on the vaporization log to assure that cylinders with prohibited valves are not heated. (An Order issued by the NRC prohibits the heating of UF6 cylinders fitted with valves of certain lots manufactured by Superior Valve Co.)

No violations or deviations were identified.

b. Tours During the inspection, tours were made of the various work areas to observe operations. Items reviewed or verified included:

(1) Special nuclear material was stored in arrays on carts, and in designated storage locations in accordance with posted instructions.

(2) Scales used for control of special nuclear material had been calibrated and had stickers affixed indicating the next calibration due date.

(3) Housekeeping in all areas was acceptable. New floor coatings had been applied in the scrap processing area.

(4) Differential pressure readings in filters and enclosures were within the authorized limits.

No violations or deviations were identified.

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c. Fuel Handling and Storage During tours of the production areas, the inspector observed the handling of pellets, fuel rods, and fuel assemblies. All observed activities were in accordance with posted safety limits and storage requirements. Coupleted assemblies were stored in pernanent fixtures. Storage and transport of completed rods were in accordance with the license requirements for slab thickness and unit separations.

No violations or deviations were identified,

d. Fan Failure On November 23, 1987, the licensee notified Region II by telephone of the failure of the incinerator exhaust fan and resulting damage to surrounding equipment. This was followed by a written report on November 24, 1987 in accordance with 10 CFR 20.403(b).

The licensee conducted an investigation of the cause of the failure, including metallurgical examinations of the parts. The inspector reviewed the summary report of the investigation and discussed the remedial actions with licensee representatives. The inspector had no further questions.

No violations or deviations were identified.

9. Procedures (88005, 88015, 88025)

a. The inspector verified that procedural controls are in place establishing the Regulatory Af fairs procedure system (RA-001 and RA-110), the training of Regulatory Affairs personnel (RA-105), the performance and review of nuclear criticality safety analyses (RA-300), and control and testing of the nuclear criticality alarm system (RA-304). Other procedures exist for management controls and assignment of responsibilities. The inspector reviewed selected procedures and verified that they were reviewed and approved as required by internal procedures and the license.

No violation or deviations were identified.

b. The inspector reviewed one new procedure and revisions to three procedures. All of the procedures were reviewed and approved in accordance with the internal procedures and the license. The scope of changes were consistent with the regulations and the license.

No violations or deviations were identified.

10. Training (88010)

The inspector verified that the licensee has established a training policy for the plant organization (procedure CA-006), and procedures for

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Regulatory Aff airs personnel (RA-105). Radiation protection training is specified in RA-214. In reviewing internal documents and discussions with managers, the inspector determined that special topics are covered in work place meetings or training sessions as necessary.

No violations or deviations were identified.

11. Review of the Operational Safety Assessment Findings (92701)

a. An Operational Safety Assessment was conducted by the NRC at the licensee's facility in January 1987. Findings of the assessment were reported in Inspection Report 70-1151/87-01. By letter dated May 21, 1987, the licensee responded to the assessment findings and described the corrective actions being taken on the identified weaknesses and the improvement items.

b. The inspector reviewed the status of the corrective actions with licensee representatives. The licensee has placed these items into the computerized Commitment Tracking System, and has identified responsible individuals and target completion dates for each time.

For those items which have been completed, the tracking system

, identifies the action and completion date. The status of open items is periodically updated.

c. The following IFIs identified in the Operational Safety Assessment were also reviewed during the inspection.

(1) (0 pen) IFI 87-01-03, Control of Moderating Materials in SNM Areas. The procedure for controlling moderating materials (RA-303) is still in review / concurrence. Cognizant individuals stated that the procedure should be issued by April 1988.

(2) (Closed) IFI 87-01-05, Qualifications of Individuals Who Perform Nuclear Criticality Safety Analysis. The licensee had developed a training and qualification checklist, which included supervisory and management sign-offs for specific items and for completion of the program. This checklist was incorporated into procedure RA-105, "Regulatory Affairs Indoctrination and Training," ano approved by the Plant Manager.

(3) (Closed) IFI 87-01-07, Authorization for Use of Hydrogenous Fire Fighting Agents. Site Emergency Plan Procedure CSEP-003, "Columbia Site Emergency Procedure Fire Control" was revised to designate the individuals who may authorize the use of hydrogeneous materials to fight a fire.

(4) (Closed) IFI 87-01-21, Incompatible Chemicals in Common Diked Areas. Two of the three sets of tanks in the diked area in l question are empty and out of service so incompatible chemicals l are not present. Cognizant managers advised the inspector that l removal or relocation of the tanks is being considered. If combustible gas is reintroduced, it will be after the tanks are relocated.

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Based on the licensee's review and an insurance inspection recommendation, the oil house will be relocated and the new facility will provide separate storage for flammables, oxidizers and acids.

(5) (Closed) IFI 87-01-22, Potential Release from the Anhydrous Ammonia System. A corporate hazards study group reviewed the anhydrous ammonia system and determined that no serious hazard existed. While a scenario could be developed for water to enter the system, the probability was considered low. Emergency brigade procedures provide instructions for suppressing a release from the safety valves on the tanks, and normal off-site coordination with other agencies would be in effect.

(6) (Closed) IFI 87-01-25, IFI 87-01-26, and IFI 87-01-27. These three items- all dealt with specific recommendations concerning instrument calibrations. The inspector reviewed procedures-MCP-202002 and MCP-202034 (which superseded FP-226 and FP-236),

and determined that the actions specified in the licensee's response had been completed.

(7)' (0 pen) IFI 87-01-29, Testing of Pressure Relief Valves. As noted in Report No. 70-1151/87-10, a supplemental response to this item was submitted on July 13, 1987. The inspector observed that new pressure relief valves had been installed on the ADU vaporizers. A procedure for the periodic inspection and a . testing of these valves is being prepared and is projected for issue in April.

(8) (Closed) IFI 87-01-32, Sampling Diesel Fuel Storage Tanks. The diesel fuel tanks were sampled and analyzed during the last preventive maintenance period and no organic or biological contamination was found. This sampling requirement has been entered into the master maintenance schedule for future work.

(9) (0 pen) IFI 87-01-34, Complete Modifications Identified by the Risk Assessment Committee. The three modifications covered by this item are installed but the calibration and checks for the monitors associated with two of the modifications have not been

, completed.

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