ML20151U477
| ML20151U477 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 08/26/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20151T067 | List: |
| References | |
| 70-1151-98-06, 70-1151-98-6, NUDOCS 9809110018 | |
| Download: ML20151U477 (15) | |
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.t U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.:
70-1151 License No.:
SNM-1107 Report No.:
70-1151/98-06 Licensee:
Westinghouse Electric Corporation Facility:
Comercial Fuel Fabrication Facility Columbia SC 29250 Inspection Conducted:
August 3-7. 1998 Inspectors:
D. Ayres. Senior Fuel Facility Inspector D. Seymour. Senior Fuel Facility Inspector R. Swatzell Fuel Facility Inspector Approved by:
E. McAlpine. Chief Fuel Facilities Branch Division of Nuclear Materials Safety IMl,
l EXECUTIVE
SUMMARY
Commercial Nuclear Fuel Division NRC Inspection Report 70-1151/98-06 The primary focus of this inspection was the observation and evaluation of the licensee's programs for operational safety, radiological controls, and facility support. The report includes inspection efforts of three regional inspectors. The inspection identified the following aspects of the licensee programs as outlined below:
Plant Ooerations Operations for powder production and nitrate waste / recycle handling were being performed with an adequate emphasis on established safety controls (Section 2.a).
The implementation of computerized tracking for revised drawings was a Configuration Management system improvement (Section 2.b).
Engineered and administrative (procedural) controls were being used in the Ammonium Diuranate (ADU) conversion process as identified in the Integrated Safety Analysis (ISA) (Section 2.c).
Manaaement Controls lhe licensee's procedural control system ensured that safety significant procedures were adequately reviewed by management (Section 3.b).
Waste Manaaement The low level radioactive waste program was adequately implemented and provided the information needed to ensure safe shipment and disposal of the waste (Section 4).
Transoortation Procedures for packaging and shipping radioactive materials were adequate to ensure proper characterization of the package contents.
Monitoring, marking, and labeling of fuel assembly packages were adequate to properly communicate the level of hazard associated with the packages (Section 5.a).
l The delivery of completed packages to carriers adequately addressed safety for subsequent transport and receipt (Section 5.b).
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2 Trainina General employee training program included the topics required by 10 CFR 19.12. but failed to provide required training / instructions to all applicable workers (Section 6).
Attachment:
Persons Contacted List of Items Opened. Closed, and Discussed List of Acronyms i
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i REPORT DETAILS 1.
Summarv of Plant Status This report covered a one week period.
Powder. pellet, and fuel assembly production proreeded at normal rates. There were no unusual plant operational occurrences during the onsite inspection.
2.
Plant Ooerations (IP 88020) (03) a.
Conduct of Operations (03.01)
(1)
Inspection Scope Process tours were performed to verify the conduct of operations was being safely controlled througa the use of area postings and operating procedures.
(2)
Observations and Findings The inspector reviewed operations in the powder production and nitrate waste / recycle handling areas. The inspector also reviewed Chemical Operating Procedures for UFs vaporization. Ammonium Diuranate (ADU) calcination, and the i
L operation of the calciner scrubber system. The inspector l
also observed safety postings throughout the powder production and nitrate waste / recycle handling areas. The inspector found no deviations from established safety controls for operations in those areas.
(3)
Conclusions-Operations for powder production and nitrate waste / recycle handling were being performed with an adequate emphasis on i
established safety controls.
b.
Facility Modifications and Configuration Controls (03.02) l (1)
Inspection Scope A review of facility modifications conducted since January 1998, was conducted to ensure the safety bases were being l
adequately documented and updated.
l (2)
.0bservations and Findings i
The inspector reviewed the licensee's procedure for conducting facility modifications. The inspector also observed the operation of a recently implemented 5
computerized tracking system for the completion of facility drawings. The inspector found that this facility drawing tracking system helJed ensure that engineering projects were not closed before t1e drawings had been revised.
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The inspector reviewed the configuration management (CM) projects completed since January 1998.
The inspector chose j
the most safety significant project for further investigation. This project involved the redesign of a motor used in the powder production and pelleting areas.
J The redesign, in part, was performed to reduce airborne contamination.
T1e inspector found that although a computerized tracking system had been established for l
facility drawings, no such tracking system had been established for other types of documentation (spare aarts lists, operating procedures, software codes, etc.) clanged l'
as a result of a CH aroject.
Since the motor redesign i
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' project involved a clange in the spare parts list. the inspector reviewed the warehouse inventory records and verified the spare parts description had been appropriately revised.
l The inspector reviewed the safety controls described in the licensee's safety basis documentation for the ADU Conversion areas. The inspector observed that no unauthorized changes j
to the safety significant passive engineered and procedural controls had occurred.
(3)
Conclusions The implementation of computerized tracking for revised i
drawings was considered a CM system improvement.
Projects reviewed for 1998 were being completed per orocedures to j
ensureconsistencyandaccuracyofthefacilitysafety i
basis.
l c.
Implementation of Process Safety Controls (03.03)
I (1)
Inspection Scope The ADU conversion process was reviewed to verify adequate L
implementation of process safety controls.
(2.)
Observations and Findings The inspector reviewed the ISA for the ADU conversion process dated July 31, 1998.
The inspector observed that the ISA identified the process controls relied upon for criticality safety. The inspector observed during process t
tours that all passive engineered controls identified in the l
ISA were as described and available to perform their j
specified safety function.
L The inspector reviewed the various ADU conversion process operating procedures.
The inspector noted that all f
administrative process safety controls listed in the ISA as
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3 defenses to initiating events were present in the operating procedures.
The inspector also reviewed process log sheets and observed where operators and supervisors had verified that procedural controls were being used.
This confirmed Lne implementation of a number of the procedural controls in the operation of the process.
(3)
Conclusions Engineered and administrative (procedural) controls were being used in the ADU process as identified in the ISA.
d.
Review of Previous Events (03.07)
(1)
Inspection Scope The licensee's evaluation and corrective actions for two previously reported events were reviewed for adequacy to prevent recurrence.
(2)
Observations and Findings The inspector reviewed the licensee's evaluation of an event involving the spillage of U0 powder as reported in NRC 2
Event Notice No. 34460.
The licensee identified the cause of the spillage as being due to the vibration-induced failure of an undersized light-duty clamp used to hold the end cap onto a powder line clean-out port. The inspector observed that most such clean-out ports used a more substantial heavy-duty style clamp for securing end caps.
The licensee indicated that the light-duty clamp had been used as a realacement for the heavy-duty clamp at times in the past. T1e licensee also indicated that only heavy-duty clamps would be specified for future use on powder line clean-out ports, with no substitutions allowed.
The inspector discussed the CM imalications of this event with the licensee and determined tlat the existing program for "like kind" replacements should have prevented the light-duty clamp from being used. The licensee acknowledged that the CM system should prevent such occurrences and would review the lessons learned from this event with appropriate licensee staff.
The licensee also stated that the light-duty clamps had been installed before recent improvements.
were made in the configuration management program.
The ins]ector also reviewed the licensee's response to Event Notice io. 34533 where double contingency could not be demonstrated for a UF vaporizer. The vaporizer relied upon 6
preventing UFs leaks and the accumulation of liquid condensate in the steam chest to demonstrate double contingency. The NRC was r.otified of the event when a
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4 routine shutdown maintenance check revealed the condensate drainage systa was partially plugged. thus restricting flow i
of liquids from the steam chest. The inspector observed the i
operation of the vaporizer system and the licensee demonstrated the methods used "to verify adequate operability i
of the condensate drainage system during UFs vaporization.
The ins)ector determined that the condensate handling system was pro) ably functioning adequately while processing the l
most recent UFs cylinders using pressurized steam. However.
I the degraded condition of the condensate drainage line was accentuated when non-3ressurized water was used in the maintenance check. T1e licensee *s Root Cause evaluation was incomplete at the conclusion of this inspection, but was reviewed and evaluated during a subsequent inspection (NRC Inspection Report (IR) 70-1151/98-204).
(3)
Conclusions The licensee *s response to event No. 34460 was adequate to prevent future improper clamp replacements. The lessons learned concerning "like kind" replacements are to be reviewed with appropriate licensee staff. The licensee's response to event No. 34533 was still under investigation.
e.
Follow-up on Previously Identified Issues (03.08)
(1)
Inspection Scope Several previously identified issues were reviewed for possible closure.
(2)
Observations.and Findings The licensee *s previous Criticality Safety Evaluation (CSE) had listed the dewatering centrifuge amperage switch as a j
protection against initiating events, but the switch had never operated satisfactorily and was removed from the process equipment.
Inspector Follow-up Item (IFI) 97-03-01 tracked the effort to revise the safety analysis for this equipment. Also. IFI 97-03-03 tracked the licensee *s effort to include all changes to the ADU Conversion as supplemental information to the CSE. The inspector's review of the ISA in Section 3.b of this report verified that the switch was deleted from the list of safety controls, thus IFI 97-03-01 can be considered closed.
Also, since the CSE for ADU Conversion was obsoleted with the development of the ISA, and since the ISA is required by license conditions to be maintained as accurate, the need for CSE su)plements is no longer valid.
Thus. IFI 97-03-03 can also se considered closed.
d
5 The inspector reviewed the licensee's actions taken in response to IFI 98-02-01 to help prevent inadvertent deletion of required preventive maintenance (PM) activities.
The licensee assigned specific technical services engineers to monitor the PM activities o~f specific categories of safety related equipment to ensure no unauthorized deletions occurred. The inspector found that such assignments can usually be effective only in the short term unless programmatic commitments are made to monitor PM activities through the use of maintenance procedures etc.
IFI 98-02-01 can be closed, but future inspections of the licensee's maintenance program will include revisiting this issue to determine the effectiveness of the actions taken.
The inspector reviewed the licensee's actions for addressing the failure of a recirculation alarm on a bulk Uranyl Nitrate (UN) tank (IFI 98-03-01). This item had been assigned to an appropriate engineer, but was not scheduled to be completed until August 31, 1998. Thus IFI 98-03-01 will remain open. The inspector also reviewed the licensee's progress on assessing the adequacy of its post-maintenance functional testing of process equipment and control software (IFI 98-02-03). and the completion of corrective actions associated with a violation (VIO) for failure to follow required work controls (VIO 98-02-02).
Both of these items were not yet completed and will remain open.
(3)
Conclusions Licensee actions have been completed for three previously identified issues: IFI 97-03-01. IFI 97-03-03, and IFI 98-02-01 can be closed.
Incomplete licensee actions in response to IFI 98-03-01. IFI 98-02-03. and VIO 98-02 ^2 will require that these items remain open.
3.
Manaaement Controls (88005) (05) a.
Organizational Structure (05.01)
(1)
Inspection Scope Changes in organizational structure and personnel responsibilities were reviewed to determine safety significance.
l (2)
Observations and Findings The inspector reviewed the current organizational structure and found it to be essentially unchanged since the appointing of the current Plant Manager in 1997.
- However, i
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6 the licensee was pursuing some organizational changes in response to IFI 98-202-02 concerning the adequacy of the existing organizational structure in implementing its Safety Margin Improvement Program.
(3)
Conclusions No significant organizational changes occurred since the last review of the licensee *s organizational structure.
b.
Procedural Controls (1)
Inspection Scope The licensee's system for reviewing and approving procedures was evaluated for its ability to accurately instruct workers on safety significant actions.
(2)
Observations and Findings The inspector observed the licensee's computerized procedure control system and coordinator remained unchanged since the last review during a previous inspection (IR 70-1151/97-05).
The system continued to be adequate for assuring that only the proper procedural revisions were available to workers.
The inspector reviewed a number.of operating and maintenance procedures and found no safety significant problems with the licensee's staff review and approval routings.
(3)
Conclusions The licensee's procedural control system ensured that safety significant procedures were adequately reviewed by management.
4.
Waste Manaaement (R3) (84850) l'aste Classification (R3.06). Waste Form Characterization (R3.07). Waste Sr.ipping (Manifests. Labeling, and Surveys) (R3.08). Tracking of Waste Shipments (R3.09), and Quality Assurance Programs (R3.10) a.
Inspection Scope The inspectors reviewed the licensee's procedures and methods for determination of waste classification and waste characterization, and also reviewed shipping manifest records for disposal of solid radioactive wastes. Waste classification, characterization, and the waste manifests are important, in part, because accurate and complete information supports the most effective response to i
transportation emergencies, and provides the receiver with the information needed to safely handle and dispose of the waste.
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7 b.
Observations and Findings The ins]ectors toured the facility where low level radioactive waste (_LRW) was stored awaiting shipment (or processing) and found that the structural stability'and storage arrangement of the containers (55 gallon drums) was acceptable with no distinguishable corrosion or swelling characteristics.
No susceptibility to water infiltration or unstable stacking of the LLRW drums was observed.
In addition the drums had sufficient i
labeling and the temporary holding locations were identified with the appropriate radioactive material signs. The licensee stated l
that essentially all of the wastes shipped from this facility was classified as Class A waste per 10 CFR 61.55 specifications.
The inspectors reviewed data from two methods used by the licensee for assessment of waste container uranium isotopic (U-234.- U-235.
and U-238) mass and activity content.
Several examples of these methods were reviewed and no inconsistencies were identified.
The inspectors also reviewed Uniform Low-Level Radioactive Waste Manifests (Forms 540 and 541) for three 1998 shipments to verify that the requirements specified in 10 CFR Part 20. Appendix G.
Requirements for Transfers of Low-Level Radioactive Waste Intended for Disposal at Licensed Land Disposal Facilities and Manifests.
were met. No safety significant discrepancies were identified.
The inspectors reviewed the licensee's most recent audits for l
their Low Level Radioactive Waste program to verify that the i
licensee had established and maintained an acceptable Quality i-Assurance Program per 10 CFR Part 20 Appendix G and 10 CFR 61.55 and 61.56 requirements. The review of audits conducted in 1995 and 1996 showed that management evaluations were performed.
No y
significant discrepancies were identified.
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c.
Conclusions
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The low level radioactive waste program was adequately implemented and provided the information needed to ensure safe shipment and disposal of the waste.
5.
Transoortation (86740) (R4) a.
Preparation of Packages for Shipment (R4.01)
(1)
Inspection Scope A review of packaging marking, package labeling, and radiatica monitoring was conducted to verify proper l
dispositioning of safety significant shipments.
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8 (2)
Observations and Findings The inspector reviewed the licensee's procedures for packaging and shipping of fuel assemblies and other l
radioactive materials. The inspector found that the l
instructions for marking, labeling, and monitoring radiation levels of packages were consistent with the safety i
significant requirements of 49 CFR Parts 172 and 173. The inspector observed the packages used for shipping fuel assemblies and found the markings on each identified the proper shipping name and identification number of the paccaged hazardous material: the reportable quantity designator: the shipper's name and location: and each container's type, model number, serial number, and maximum l
gross weight.
The inspector observed the loading of a truck with packaged fuel assemblies. The inspector observed the radiation surveys for removable surface contamination of each package and the external gamma radiation monitoring at the surface l
and one meter from the surface of each package, The l
inspector found that the surveys were properly performed.
l and the survey results were converted into the proper hazard l
category for labeling of each package. The inspector also observed that the proper type and number of hazardous i
materials labels were applied to each package.
(3)
Conclusions L
The licensee's procedures for packaging and shipping l
radioactive materials were adequate to ensure proper i
characterization of the package contents. The licensee's l
monitoring, marking, and labeling of fuel assembly Jackages were adequate to 3roperly communicate the level of lazard 1
associated with tie packages, t
l b.
Delivery Of Completed Packages To Carriers (R4.02) i (1)
Inspection Scope The licensee's documentation and vehicle loading practices associated with completed packages were reviewed for performance of safety related requirements.
l (2)
Observations and Findings The inspector reviewed the licensee *s documentation for a variety of radioactive material shipments. The inspector i
observed that shipments of fue' assemblies. UFs cylinder heels, empty UFs ylinder overpacks, and containers of Low c
Specific Activity waste were all documented with the
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9 l-information required to assure safety of transport and recei)t. The inspector observed the placing of fuel assem]ly Jackages on a vehicle and found that they were properly ) locked and braced to ar,sure safety of the public during normal transport.
(3)
Conclusions The licensee's delivery of completed packages to carriers adequately assured public safety during transport and receipt.
6.
Trainino (88010) (F2)
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10 CFR 19.12 Training (F2.01). General Nuclear Criticality Safety Training (F2.02). General Radiological Safety Training (F2.03), and General Emergency Training (F2.04) a.
Inspection Scope The licensee's general employee training was reviewed to verify it included the topics required by 10 CFR 19.12.
Part 19.12 of Title 10 of the Code of Federal Regulations requires workers who are likely to receive an occupational dose in excess of 100 millirem receive specific instruc-tions.
This training helps ensure that plant workers have the basic information needed to deal with potential radiological health protection problems that may occur in the workplace.
b.
Observations and Findings The inspectors determined that the licensee's training for new l
employees consisted of two videos. One video was resented to all new employees, the second was presented to new emp oyees who were going to work in the chemical or the encapsulated uel manufacturing areas.
The inspectors viewed the two videos to determine if they met the requirements in 10 CFR 19.12 and discussed the video contents with the licensee trainers.
The inspectors concluded that the videos included the instructions to workers required by 10 CFR 19.12. However, during subsequent discussions with the licensee, the inspectors determined that personnel working in the manufacturing area of the facility could change jobs and move into positions in the encapsulated fuel portion of the manufacturing area, and not receive the training i
l recuired by 10 CFR 19.12 (i.e., they viewed only one of the two viceos).
This meant that these workers (three examples were identified by the licensee as a result of the inspectors' inquiries) did not receive all the basic information needed to deal with potential radiological health protection problems that might occur in the workplace. The inspectors
- primary concern was
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10 that the training program for new employees (or employees changing job positions) was not structured to ensure the employees received necessary training. This failure to instruct the workers is identified as a violation (VIO 70-1151/98-06-01).
The licensee provided the needed training to the three employees on August 7. 1998.
Other planned corrective actions included strengthening the training program by implementing controls to verify needed training is received when transferring an employee between areas or when an employee returns to work after a disability. The licensee also plans to perform an in-depth internal audit to verify that all general employee (new employee) training requirements in 10 CFR 19.12 and the License Application j
are effectively implemented, i
c.
Conclusions Based on this review, the inspectors concluded that general employee training included the topics required by 10 CFR 19.12.
One violation was identified for the failure to provide required l
training / instructions to all applicable workers. The training program for new employees (or employees changing job positions) was not structured to ensure the employees received necessary training.
7.
Exit Interview (30703) (M1)
On August 7. 1998, the inspection scope and results were summarized with licensee representatives.
The inspector discussed.-in detail, the i
routine program areas inspected and the inspection findings, including any apparent violation (s).
The licensee identified some of the materials provided during the inspection as proprietary, although proprietary information is not contained in this report.
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j ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee
- J. Allen. Plant Manager
- J. Bush. Manager. Manufacturing l
- S. Gantt Sr. Regulatory Engineer
- W. Goodwin. Manager. Regulatory Affairs l
- J. Heath. Manager. Regulatory Engineering and Operations
- E. Lacy. Manager. Plant Systems Engineering l
- R. McCormac Chemical Process Engineering l
- N. Parr Manager Chemical Process Engineering l
- T. Ross Manager. Transportation
- T. Shannon Regulatory Affairs Technician Other Licensee employees contacted included engineers, technicians. security l
and office personnel.
- Attended exit meeting l
INSPECTION PROCEDURES USED IP 84850 Inspection of Waste Generator Requirements IP 86740 Inspection Of Transportation Activities IP 88020 Region Nuclear Criticality Safety Inspection Program IP 88005 Management Organization and Controls IP 88010 Operator Training / Retraining IP 92701 Follow-up on Inspector Problems IP 92702 Follow-up on Violations / Deviations l
LIST OF ITEMS OPENED CLOSED, AND DISCUSSED Ooened l
70-1151/98-06-01 VIO Failure to Provide Adequate Safety Training (Section 6).
Closed l
70-1151/97-03-01 IFI Follow-up on Testing of the Centrifuge Instrumentation (Section 2.e).
70-1151/97-03-03 IFI Follow-up on Actions to Supplement CSE Documents (Section 2.e).
. 1151/98-02-01 IFI Follow-up on Actions to Prevent Deletion of Required Programmed Maintenance (Section 2.e).
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2 Discussed 70-1151/98-03-01 IFI-Review Licensee *s Actions to Prevent Common Failure of Uranyl Nitrate Recircula, tion Pump Alarm System (Section 2.e).
i 70-1151/98-02-02 VIO Several Examples of Failure to Follow Required Work Controls (Section 2.e).
70-1151/98 02-03 IFI Follow-up on Actions to Assess the Adequacy of Post-Maintenance Functional Testing of Process Equipment and Control Software (Section 2.e).
LIST OF ACRONYMS AND ABBREVIATIONS
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ADU Ammonium Diuranate s
+
CFR Code of Federal. Regulations CH-Criticality Management CSE Critical' Safety Evaluation IFI Inspector Follow-up Item IP Inspection Procedure IR Inspection Report
-ISA Integrated Safety Analysis LLRW Low Level Radioactive Waste NRC Nuclear Regulatory Commission PM Preventative Maintenance
' UFs Uranium Hexafluoride UN Uranyl Nitrate.
00 Uranium Dioxide VIb Violation I
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