ML20149F910

Insp Rept 70-1201/97-05 on 970616-20.No Violations Noted. Major Areas Inspected:Observation & Evaluation of Licensee Programs for Operation Safety,Mgt Organization & Controls, Conduct & Control of Maint & Testing of Safety Equipment

ML20149F910
Person / Time
Site:	07001201
Issue date:	07/11/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20149F905	List: ML20149F900 ML20149F910
References
70-1201-97-05, 70-1201-97-5, NUDOCS 9707220361
Download: ML20149F910 (15)

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L U. S. NUCLEAR REGULATORY COMMISSION L

i REGION II l

Docket No.: 70-1201 License No.: ~SNM 1168 Report No.: 70 1201/97-05 l

Licensee: B&W Fuel Company l

Facility: Commercial Nuclear Fuel Plant 1 i

Location: Lynchburg, VA

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o- Date: June 16 20, 1997 Inspectors: C. Bassett, Senior Radiation Specialist D. Ayres. Fuel Facilities Inspector l Approved by: E. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety l

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l Enclosure 9707220361 970711 PDR ADOCK 07001201 C PDR

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l Executive Summary B&W Fuel Company NRC Inspection Report No. 70-1201/97 05 The primary focus of this inspection was the observation and evaluation of the licensee's programs for operational safety, management organization and l controls, conduct and control of maintenance and surveillance testing of '

safety equipment, and various safety training courses. The report includes inspection efforts of two regional inspectors. The ins)ection identified the following aspects of the licensee programs as outlined aelow:  ;

PLANT OPERATIONS e Plant operations were being performed safely. Safety postings were being followed except for an instance where moderating materials were found to be stored in the fuel assembly area (NCV 97 05 01).

e Housekeeping was found to be adequate to minimize fire load in areas containing licensed material and to ensure routes of egress were clear.

e Unresolved Item (URI) 70 1201/97 03 02 was closed when it was concluded that the use of nylon straps did not affect the overall k,rr of the system beyond the analyzed condition.

MANAGEMENT ORGANIZATION AND CONTROLS e Due to a conflict between the proposed organizational changes and the License Application, the Manager of Health / Safety and Licensing will continue to report to the Plant Manager until a license amendment allowing otherwise is a) proved by the NRC. Otherwise, no problems were noted with the recent clanges that had been made in the licensee's organization. The recently appointed individuals were aware of their responsibilities with respect to nuclear criticality safety.

e The licensee was revising and approving new and existing procedures in accordance with the License Application and applicable procedures. The licensee identified two cases where procedures were not being reviewed at the required frequency (NCV 97 05 02).

e The Safety Review Board (SRB) was composed of the vmbership required by the License Application, and was reviewing the appropriate safety-related topics and issues. The SRB meetings were being held at the required frequencies.

MAINTENANCE / SURVEILLANCE e The licensee has conducted preventative maintenance (PH), surveillance testing, and calibrations of safety-related ecuipment within the scope of the license application and internal procecures. However, plant controls on PM, surveillance testing, and calibrations of safety related equipment are scattered through different systems, making it difficult to ensure the completeness of safety related maintenance.

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, . l TRAINING e .The licensee's workers were receiving the training courses required by the Employee Safety Training procedure. However, workers were not always properly notified as to when their training was to expire.

e The training materials available for inspection were insufficient to confirm compliance with requirements and will be further examined during a subsequent inspection (URI 97-05 03).

Attachment:

Persons Contacted Inspection Procedures Used List of Items Opened, Closed, and Discussed List of Acronyms I

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Reoort Details

1. Plant Operations (03) (88020) i a

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{' a. Conduct of Ooerations (03.01) l i

(1) Insoection Scope t l The inspectors toured the licensee's operations and storage

! areas to confirm that actions required by the License Application and pertinent procedures were being performed to

, assure safety.

5 (2) Observations and Findinas o The inspectors observed the rod downloading operations being

! performed on NUKEH assemblies. The rod end cutting operation was observed to be performed using pro >er safety equipment and procedures. The inspectors also o) served a posting of the most recent smear survey of the area, which gave the o>erators good information on potential trouble spots of tie operation that may produce spreadable contamination. The inspectors also observed the pellet dumping station, where the opened rods are tilted and l vibration is applied to facilitate the removal of. the 1 pellets from the NUKEM rods. The >ellets fell into a l plastic bag placed inside a glove )ox. When filled, the plastic bag was wiped down (as much as possible) and dropped into a cardboard box for packaging. The cardboard box was 1 removed from the glove box, labeled, and packaged in an outer plastic wrapping.

The inspectors observed that the plastic bag, when .illed with pellets inside the glove box, was too heavy to.be lifted while working through glove > orts, so that any dust on the bottom of the bag could not ye wiped off. The inspectors also observed that stationary air samplers had been turned off in the area where the filled cardboard boxes were labeled and wrapped with plastic. The inspectors inquired about the air sampling philosophy and were informed that the stationary air samplers were activated based on results of lapel air samplers worn by the operators.

The inspectors were concerned about potential air activity in the pellet unloading area due to the vigorous shaking of the rods needed to remove the pellets and the inability to completely wipe off the outside of the plastic bags into which they were dumped. The inspectors were also concerned  ;

with the philosophy used for operating stationary air samplers since current year Radiological Deficiency Reports issued by the licensee show cases of elevated air activity associated with the pellet downloading operation, and other such reports show t W some individuals in other areas do J

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2 not always properly wear their lapel samplers. This situation will be monitored in future inspections until the downloading operation has been completed The inspectors observed the normal rod loading and handling operations areas and found that safety devices in these areas ap) eared to be operating within normal parameters.

One slig1t deviation from plant policy concerning the demarcation of a combustible waste storage container area was found in the rod loading area and was immediately corrected by the licensee.

The inspectors observed the fuel assembly storage areas for compliance with area postings. Stored fuel assemblies and fuel assembly shipping containers were found to be properly spaced and secured in designated locations. However, six plastic hard hats were found to be stored in the fuel assembly storage area, some within inches of a fully loaded assembly. This situation violated the criticality safety posting which stated that moderating materials (including plastics) must not be stored in the area. A similar situation was found on a previous inspection (see Inspection Report (IR) 70 1201/97 03, and VIO 70 1201/97 03 01) involving the storage of nylon straps in the area. This previous violation was still open pending completion of the licensee's corrective actions. Since the safety significance of the as found condition was considered to be low, and since corrective actions were already under way to correct a similar situation, this NRC identified violation is not being cited because criteria specified in Section VII.B of the NRC Enforcement Policy were satisfied (NCV 70-1201/97 05 01).

The inspectors observed the pellet receiving area with a delivery truck parked in the receiving bay. The inspectors  ;

were shown the internals of some of the barrels used for shipping boxes of pellets and observed the devices used to l ensure the spacing and moderation control of the licensed material during shi > ment. The inspectors observed that i safety devices in t1e pellet receiving area were being used '

and were functioning were being followed. properly, and that posted instructions ]

The inspectors observed the scrap pellet storage trailers located outdoors. One additional trailer had been added since the last inspection of this area and was found to have ,

its associated safety rules properly posted. Some of the l postings on the other scrap 3ellet storage trailers were l found to be weather worn wit 1 their legibility fading. One  !

posting was found such that the ta>e used to secure it to the trailer door obscured one of t1e instructions. The inspectors notified the licensee of these potential problems and the postings were replaced with clearly legible ones.

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3 The inspectors observed operations in SERF 4 from the control room window. The reconditioning of equipment used to shape power reactor steam generator tube plugs was being conducted. All observable workers in the contaminated areas were wearing proper anti c clothing and lapel air samplers '

per the radiation work permit.

(3) Conclusions Overall, plant operations were being performed safely.

Safety postings were being followed except for the instance where moderating materials were found to be stored in the fuel assembly area. The licensee reacted quickly to remedy most of the potential problem areas found by the inspectors.

b. Housekeepina (03.06)

(1) Insoection Scope The inspectors reviewed plantwide housekeeping for stored hazardous or combustible materials and to ensure that emergency egress routes were not blocked by storage of 1 materials.

J (2) Observations and Findinas The inspectors observed the storage of hazardous materials in designated locations and cabinets with no 3roblems noted.

The inspectors observed the large number of slipping and storage containers used by the specialized equipment refurbishment facility. Filled containers were neatly stacked on indoor racks. Empty containers were mostly stored outdoors in various areas, and although gave a cluttered appearance to certain locations, did not affect ,

the routes of egress from the facility.

ectors observed the refurbishment of 55 gallon The insp/ shipping drums in the S2 building.

storage Refurbishment involved removal of old labels and repainting the outer surfaces of the drums. Although several dozen drums were refurbished during the inspection period, egress routes were i not obscured and the area was neatly cleaned at the end of l each day. i l

(3)

Conclusion:

Housekeeping was found to be adequate to minimize fire load in areas containing licensed material and to ensure routes j of egress are clear.

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c. Followuo of Previously Identified Issues (03.081 (1) Summary of Concern URI 70 1201/97-03-02 involved the consideration of effects of using moderating materials (nylon straps) in the fuel assembly storage area. This situation could not previously be assessed by the inspectors which found the apparent unanalyzed condition due to insufficient information.

(2) Observations and Findinos The inspector reviewed a report prepared by the licensee's criticality safety contractors. The inspectors found that although nylon straps were not specifically evaluated in the criticality analysis for storage of NUKEM assemblies, the analysis does show that an infinite 2 D array of NUKEM fuel assemblies has a k,,, <.95 for all degrees of interspersed moderation.

(3) Conclusions The inspector concluded that the use of nylon straps did not affect the overall k ,, of the system beyond the analyzed condition. URI70lh01/9703-02 is closed.

2. Management Organization and Controls (05) (88020)

a. Oroanizational Structure (05.01)

(1) Inspection Scope The inspectors reviewed the licensee's organizational structure to determine whether changes made since the last inspection at the facility were in compliance with the License Application.

(2) Observations and Findinos During the inspection the inspectors were provided with a copy of a new organizational structure that had recently gone into effect at the facility. It was noted that changes had been made to the organization since the last NRC Region II inspection. The person that had been selected to fill the position of Plant Manager was new to the position and the facility but not new to the company itself. It was also noted that the organizational structure had been changed in that the Manager, Health / Safety and Licensing was no longer reporting directly to the Plant Manager but reported to the Manager, Quality Health / Safety and Licensing. Through discussions with the individuals chosen to fill the positions of Plant Manager and Manager, Quality, a

5 Health / Safety and Licensing, the inspectors determined that they were aware of and understood their responsibilities concerning nuclear criticality safety as well as their other

'. responsibilities including production and safety in general.

The experience and background of the new Plant Manager was reviewed and the inspectors determined that he appeared to meet the qualifications specified in the License Application.

Because a change had been made in the organizational structure at the facility, the licensee was preparing a license amendment so that the License Application would reflect the changes that had been made to the original structure and to receive NRC approval. As noted above, the inspectors determined that, as a result of the change, the reporting structure in place at the facility differed from that required in the License Application since the Manager, Health / Safety and Licensing had been reassigned to report to a person other than the Plant Manager as stipulated. In response, the licensee issued an internal memorandum from the Office of the President of Framatome Cogema Fuels (FCF) dated June 19, 1997, stipulating that the Manager, Health / Safety and Licensing would continue to report to the Plant Manager in the interim until a license amendment allowing otherwise was approved by the NRC.

(3) Conclusions Except for a conflict with the pro)osed organizational reporting structure indicated in tie License Application, no problems were noted with the recent changes that had been made in the licensee's organization. The recently a> pointed individuals were aware of their responsibilities wit 1 respect to nuclear criticality safety. The Manager.

Health / Safety and Licensing will continue to report to the Plant Manager until a license amendment allowing otherwise is approved by the NRC.

b. Procedure Controls (05.02)

(1) Inspection Scooe The inspector reviewed the licensee's program for reviewing, revising, and approving new and existing procedures to ensure that procedures important to safety were being reviewed at the required frequency and approved in accordance with the License Application and applicable procedures.

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6 (2) Observations and Findinas The inspector reviewed a representative sample of safety-significant procedures that had been changed or modified within the past year. The inspector verified-that the changes or modifications to the procedures had been implemented and that the changes had been reviewed and approved by staff that had the responsibility for maintaining the procedures. The inspector reviewed a representative sample of procedures to ensure that the licensee was conducting reviews of the procedures annually as recuired by the License Application as well. Of the five procecures reviewed, two had not been reviewed on the annual basis stipulated. However, the inspector determined that the licensee had also noted this problem during a self audit conducted in February 1997. To correct this situation, a schedule had been developed to ensure that the procedures would be reviewed by the end of the year.

The inspector noted that the failure to perform an annual audit of procedures was an apparent violation of License Condition 10 of Haterials License SNM 1168 which requires the licensee to com Safety Conditions. Safety ply with all listedSconditions Condition in the 1 requires the licensee to comply with the statements, representations, and conditions in Part I of the License Application dated June 22, 1990, and su)plements thereto. Part I, Chapter 2, Section 2.6 of t1e Application, requires that health safety procedures shall be reviewed at least annually for technical correctness and applicability. The inspector informed the licensee that this licensee identified and corrected violation was not being cited because criteria specified in Section VII.B of the NRC Enforcement Policy were satisfied (NCV 70 1201/97 05 02).

(3) Conclusions The inspector concluded that the licensee was revising and approving new and existing procedures in accordance with the License Application and applicable procedures and, with the exception of two of five procedures reviewed, the licensee was reviewing existing procedures at the required frequency and in accordance with the License Application.

c. Safety Committees (05.04)

(1) Insoection Scope The inspector reviewed the safety committee that the licensee had established to ensure that the membership of the committee met the terms and conditions stipulated in Part I, Chapter 2, Section 2.3 of the License Application.

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that the committee was reviewing safety-related issues, and that the meetings were being held at the required frequencies.

(2) Observations and Findinas The inspector reviewed the minutes of the SRB meetings for the past year. It was noted that the membership of the committee consisted of rearesentatives from those c:ganizations stipulated ay the License Application (e.g.,

Manufacturing Engineering, Fuel Manufacturing, and Field Operations) and that the Board was chaired by the Manager, Health / Safety and Licensing as required. With the exception of.the fourth quarter of 1996, the SRB meetings had been held quarterly as required. (The issue regarding no SRB meeting being held during the last quarter of 1996 was also noted and addressed as a NCV in NRC IR 97 04.) The inspector noted that the SRB was reviewing safety related topics and issues as required such as: 1) facility modifications, 2) analyses of new or modified equipment and/or processes, 3) maintenance of fire safety,

4) reviewing the effectiveness of established controls and safeguards, 5) maintenance of ALARA, 6) review of audits and inspection findings, and 7) review of abnormal occurrences.

1 The inspector noted that the licensee had organized a second l

" safety committee" at the facility, the Plant Safety l Committee (PSC). The PSC was comprised of eight salaried i production workforce employees and was chaired by a. person chosen from the group. The PSC was to meet monthly and discuss such topics as: 1) accident / injury reports, 2) new or outstanding recommendations for improvements to safety, and 3) discuss and report on unfinished business of previous meetings. During this insaection, the inspector was informed that the PSC was )eing re organized and re named. .

The name of the new safety committee was to be the Safety Action Committee and it was to be composed of a representative from each organization at the facility. Each organization was to be considered a "home team" and the l representative was to be a facilitator for the "home team".

Each facilitator was to attend the Safety Action Committee meetings and keep the "home team" informed of general safety information and would be responsible.for. addressing Industrial Deficiency and Radiological Deficiency Reports with the team input.

(3) Conclusions The inspector concluded that the licensee's formal safety committee, the SRB, was composed of the membership required by the License Application, that the committee was reviewing safety related topics and issues, and that the meetings were i

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being held at the required frecuencies (with the exception noted above). The licensee hac established, and was in the process of reorganizing, a second safety committee with membership from each organization to communicate safety issues to their respective groups and address deficiency reports at the working level.

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3. Maintenance / Surveillance (F1) (88025)  !

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a. Conduct of Maintenance (F1.01). Work Control Procedures (F1.02). I and Work Control Authorizations (F1.03)

(1) Insoection Scoce l l

The inspector reviewed the conduct of maintenance on safety related equipment, the procedures / system used to control the performance of maintenance and surveillance testing, and internal inspection results and audit findings so that equipment and controls relied upon for safety will operate when needed.

(2) Observations and Findinas i

The inspector observed that the system used for controlling maintenance work and surveillance testing was a windows-based tracking and scheduling software package. Procedures for PM exist only as standard task descriptions within the software's database. These descriptions can be accessed, printed, and attached to a work authorization for specific jobs. The PM task descriptions within the maintenance database have no formal review and approval requirements.

Instead, they are developed by knowledgeable maintenance, safety, and/or engineering personnel and placed into the database.

The inspector observed that the breadth of the scope of PM tasks within the maintenance database was mainly items that were not identified as being safety related. The items that were identified in the database as " safety related" were not the major systems normally associated with NRC licensed materials (criticality alarms, ventilation, and radiation detection equipment). Instead, the items in the database marked as safety-related dealt more with standard industrial safety (emptying spent acid tanks, bleeding pressure from hydraulic lines, etc.).

The inspector observed that, unlike preventive maintenance procedures, many procedures for testing and surveillance of safety equipment were formalized and approved by licensee management. The inspector reviewed the procedures e.J associated audits for safety interlock testing, overhead crane inspections, emergency lighting inspections, portable

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9 emergency radio inventory audits, evacuation alarm testing, j emergency shower / eyewash audits, and other emergency  !

, equipment audits. The calibration records for the  !

criticality monitoring and alarm system were also reviewed.  !

The review of all of these records revealed no problems with  :

the audits that are currently performed. I 3 -

(3) Conclusions 4

The inspector concluded that the licensee has conducted PM, surveillance testing, and calibrations of safety related

equipment within the scope of the license application and 1 internal procedures. However, plant controls on PM, i surveillance testing, and calibrations of safety related L equipment are scattered through different systems. Control and documentation of these functions are dependent upon the i

group which performs them, thus making it difficult to i ensure the completeness of the maintenance, surveillance, and calibration of safety related equipment and systems.

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! 4. 10 CFR 19'12 Traininc (F2.01). General Nuclear Criticality Safety

j. Trainina (F2.02)-. anc General Radioloaical Safety Trainina (F2.03)

- a. Insoection Scope

. J. The inspectors reviewed the licensee's training 3rogram to

1 determine whether the licensee was complying wit 1 regulations and

license requirements related to the training of employees and other personnel.

b. Observations and Findinas l

4 The inspectors reviewed the licensee's Employee Safety Training  !

procedure (AS 1101, Rev.19) which outlined the training

. requirements-for the various work ~ locations and positions throughout-the plant. The training records of selected r individuals were reviewed for consistency-with the list of required training courses in exhibit A of procedure AS 1101. In each case, the training courses required for the particular job 1< - being performed had been completed.

Courses which required an annual refresher were reviewed to

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confirm that worker qualifications were up to date. One instance ,

was found where a worker's Radiation Worker Training 4

4- qualifications had expired the previous day. The inspectors

< interviewed the worker and found that he had been automatically F removed from the access list for the areas which required i

Radiation Worker Training qualification and was not allowed to p enter.those areas by the computerized access system until 0

requalified. This automatic removal from area access upon expiration of training should be adecuate for ensuring that only 1 qualified personnel enter an area. Fowever, there is not

10 currently a formal method in place whereby someone is notified of an upcoming expiration of training. The workers must remember when their training expires, or rely on their supervisor to notify them. If discovery of expired training first occurs when people need to gain access to the controlled area, it could prevent them from being able to respond to an emergency situation therein.

The inspectors reviewed the available course materials for the General Employee Safety Training. The materials consisted only of copies of a slide presentation used during the training by the instructor. Other courses were similarly documented, with no thorough training manuals available. The slide presentation materials were insufficient for the inspectors to confirm whether

, the actual training courses covered all required topics. Thus, a complete review of safety training will be deferred to a subsequent inspection when the ins xctor(s) can attend selected courses. This will be tracked as JRI 70 1201/97 05 03.

c. Conclusions The inspectors concluded that the licensee's workers were receiving the training courses required by the Employee Safety Training procedure. The licensee also had adequate controls to 3revent unauthorized personnel from entering certain potentially "

lazardous areas. However, workers were not always properly o

notified as to when their training was to expire. The training materials available for inspection were insufficient to confirm compliance with requirnments and will be further examined during a subsequent inspection.

5. Exit Interview (M1)

The inspectors ) resented the inspection results to members of licensee management at t1e conclusion of the inspection on June 20, 1997. The licensee acknowledged the findings presented. The licensee did not identify any of the information discussed as proprietary.

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ATTACHMENT

1. PERSONS CONTACTED Licensee Personnel l T. Allsep, Health Physicist

• G. Elliott, Manager, Safety and Licensing

• D. Gordon, Sr. Health Physicist R. Joseph, Maintenance Supervisor J. Matheson, Vice President, Operations i A. McKim, hanager, Quality, Health / Safety and Licensing '

• D. Minor, Manager, Manufacturing Engineering Other licensee employees contacted included engineers, technicians, operators, security, and office personnel.

• Denotes those present at the exit meeting on June 20, 1997.

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2. INSPECTION PROCEDURES USED IP 88005 Management Organization and Controls IP 88010 Operator Training / Retraining IP 88020 Regional Nuclear Criticality Safety Inspection Program IP 88025 Maintenance and Surveillance Testing

3. 1.IST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Description 70 1201/97 03 02 Closed ~ URI - Plastic materials used in the fuel assembly _ storage area not fully analyzed for their effect on k err-70 1201/97 05 01 Closed NCV Storage of plastic hard hats in fuel assembly storage area where postings state that moderating materials must not be stored.

70 1201/97 05 02 Closed NCV Failure to properly perform an annual audit of procedures.

70 1201/97 05-03 Open URI Content of required training courses could not be adequately confirmed.

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4. LIST OF ACRONYMS i

ALARA As Low As Reasonably Achievable l FCF Framatome Cogema Fuels  ;

IP Inspection Procedure  ;

IR . Inspection Reprt j NCV Non Cited Violation ,

PSC Plant Safety Committee i PM Preventative Maintenance 1 SERF Service Equipment Reconditioning Facility SRB Safety Review Board URI Unresolved Item VIO- Violation I i

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