ML20151X072

Insp Rept 70-1257/98-04 on 980810-14.No Violations Noted. Major Areas Inspected:Operational Safety,Maint & Surveillance,Transportation & follow-up of Open Items from Previous Insps

ML20151X072
Person / Time
Site:	Framatome ANP Richland
Issue date:	09/16/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151X063	List: ML20151X059 ML20151X072
References
70-1257-98-04, 70-1257-98-4, NUDOCS 9809160244
Download: ML20151X072 (12)

Text

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U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.: 70-1257 License No.: SNM-1227 Report No.: 70-1257/98-04 Licensee: Siemens Power Corporation Facility: Siemens Power Corporation Location: Richland, Washington Dates: August 10-14,1998 Inspectors: Robert G. Krsek, Fuel Facility inspector, Region til {

Wayne L. Britz, Fuel Facility inspector Approved By: D. Blair Spitzberg, Chief, Fuel Cycle / Decommissioning Branch Division of Nuclear Materials Safety

Attachment:

Supplemental Inspection Information k

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9909160244 98091g g PDR C ADOCK 07001257 '

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EXECUTIVE

SUMMARY

Siemens Power Corporation NRC Inspection Report 70-1257/98-04 This routine, announced inspection included a review of selected aspects of operational safety, maintenance and surveillance, transportation and follow-up of open items from previous inspections.

! Operations The inspectors determined that facility staff effectively implemented nuclear criticality safety and radiological safety controls throughout the plant. The inspectors also reviewed operations at the Lagoon Uranium Recovery and Solid Processing facility and i noted that operations staff were knowledgeable of the new processes and safety

interlock systems. In addition, the inspectors verified the licensee implemented new safety conditions associated with the Solids Processing facility (Section 1.1).

The inspectors concluded the licensee effectively implemented the new cylinder recertification operation. Cylinder recertification activities were in accordance with American National Standards Institute Standard N14.1. Operations staff implemented and adhered to the standard operating procedures, and the cylinder recertification activities were well documented (Section 1.2).

Maintenance and Surveillance The licensee adequately implemented a preventive maintenance program for safety related equipment. Overall, the program was effective, as demonstrated by no backlog for preventive maintenance of safety related equipment. No issues were identified with the instrument repetitive maintenance program for the nuclear criticality accident alarm system (Section 2.1).

. The inspectors concluded that the observed maintenance activities were conducted in accordance with approved procedures and radiation safety policies. Maintenance and operations staff demonstrated the ability to stop work activities when a job scope was beyond the applicability of the approved procedure (Section 2.2).

Transoortation The packaging, rework and storage of the containers was performed and documented according to procedures (Section 3.1).

The required audits were performed and issues addressed. The inspectors' concerns about investigating and determining root causes of audit items was discussed with the

quality assurance personnel. The quality assurance program was undergoing a l

, program upgrade in response to NRC Confirmatory Action Letter dated March 17,1998,

, due to previously identified concerns (Section 3.2).

l l l Report Details l Summarv of Plant Status The plant was operating Lines 1 and 2 of the dry conversion facility (DCF). Uranium recovery activities were also in operation. Fuel pellet production, fuel rod loading, and fuel bundle l i assembly operations were also in progress.

1 Operational Safety Review 1.1 Plant Operations

a. Insoection Scope (Tl2600/003)

The inspectors toured the fuel fabrication plant areas and observed general facility operations and the implementation of nuclear criticality safety requirements. The l Inspectors also reviewed selected activities for compliance with specific license

. conditions.

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b. Observations and Findinas i

l The inspectors toured and reviewed operations at the dry conversion facility (DCF), and noted that Lines 1 and 2 were operating. Line 3 was completed and ready for operation.

l The licensee had completely ceased uranium hexafluoride conversion in the UO, building. Line 1 of the wet conversion process was still undergoing equipment removal, while Line 2 was in operation only for scrap recovery operations. The pellet production and rod loading areas were also toured and operations were reviewed. The inspectors also reviewed operations in the specialty fuels building, including the solid waste uranium recovery facility. During facility tours and walkdowns, the inspectors reviewed applicable nuclear criticality safety and radiological safety requirements for each facility and operation. No nuclear criticality safety or radiological safety concerns were identified.

l The inspectors also toured and reviewed operations at the Lagoon Uranium Recovery (LUR) and Solid Processing facility (SPF). Operations at SPF were recently initiated,

and the inspectors observed and reviewed activities in these areas. The inspectors l noted that the operators in this area were knowledgeable of the new operations,

including applicable nuclear criticality safety controls and safety interlock systems associated with SPF. A review of documentation at LUR/SPF revealed that operations staff were adequately implementing the nuclear criticality safety batch controls in place for this facility. In addition, the inspectors verified that since operation of SPF, the operations staff had implemented Safety Condition S-5 of the license, which required, in l part, the periodic sampling of the onsite lagoons and independent sampling of the SPF feed tank. The purpose of the safety condition was to verify that slurry to be processed through SPF had an enrichment of less than four weight percent of uranium-235. The inspectors verified that sample results taken from the SPF feed tank and lagoons indicated a slurry enrichment of less than four weight percent of uranium-235. Finally, l

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I the inspectors reviewed operations logs and records in the LUR/SPF operations office and noted that the logs contained appropriate information for facility operation. No concerns were identified with records reviewed.

c. Conclusion

The inspectors determined that facility staff effectively implemented nuclear criticality safety and radiological safety controls throughout the plant. The inspectors also ,

reviewed operations at the LUR/SPF and noted that operations staff were i knowledgeable of the new processes and safety interlock systems. In addition, the inspectors verified the licensee implemented new safety conditions associated with the SPF.

1.2 Cylinder Recertification Facility

a. Inspection Scope (Tl2600/003)

The inspectors reviewed operations associated with the cylinder recertification facility which recently began operation. The inspection consisted of the review of operations procedures, interviews with operations staff, and observation of cylinder recertification activities.

b. Observations and Findinog The licensee began operation of a new recertification facility for type 30B uranium hexafluoride (UF.) cylinders in June 1998. As part of the inspection, the inspectors reviewed Criticality Safety Analysis No. R005, Revision 0, "UF. Cylinder recertification Operation;" Criticality Safety Specification No. P97,005, "UF, Cylinder Recertification Operation;" and Standard Operating Procedure EMF-P66,1137, "Recertification Testing and Inspection of UF. Cylinders." The new cylinder recertification facility accommodates recertification of up to 11 UF, cylinders. The inspectors reviewed and compared Standard Operating Procedure EMF-P66,1137 to American National Standards Institute (ANSI) Standard N14.1," Uranium Hexafluoride - Packaging for Transport." The inspectors noted that the method for recertification as described in Standard Operating Procedure EMF-P66,1137 was consistent with the guidance for service inspections, tests, and maintenance described in Section 6.3 of ANSI N14.1. The cylinder recertification included hydrostatic testing of the cylinder, visual cylinder inspection, ultrasonic thickness l tests of the cylinder wall thickness, and an air pressure test of the cylinder. The inspectors also verified that the three defenses for nuclear criticality safety, as i

described in Criticality Safety Specification P97,005 were implemented for the cylinder recertification facility.

The inspectors observed portions of the recertification testing for 11 cylinders

tested during the inspection. The inspectors noted in all instances that operations

, staff adhered to the specific actions of steps prescribed in the procedure. The

, inspectors also observed a National Board Certified Inspector either perform, e

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l l witness, or review specific sections of the cylinder recertification, as required by procedure. During the testing of the cylinders, one cylinder was rejected due to a cylinder wall thickness below the minimum acceptable thickness, and a second cylinder was rejected during a visual inspection due to corrosion within the cylinder.

The inspectors also reviewed other randomly selected cylinder recertification records and noted no concems.

c. Conclusion The inspectors concluded that the licensee was effectively implementing the new cylinder recertification operation. Cylinder recertification activities were in accordance with ANSI N14.1, Section 6.3, operations staff implemented and adhered to the standard operating procedures, and cylinder recertification activities were well documented.

I 2 Maintenance and Surveillance Activities 2.1 Preventive Maintenance Proaram

a. Inspection Scope (8802_5_) ,

The inspectors reviewed the overall preventive maintenance and instrument repetitive maintenance program for equipment essential to criticality safety. The inspectors specifically reviewed the instrument repetitive maintenance program for the criticality accident alarm detection system. The review consisted of walkdowns of the criticality accident alarm system, interviews with maintenance and operations staff, and reviews of preventive maintenance procedures and records.

b. Observations and Findinas The licensee implements a preventive maintenance program through the use of a commercialintegrated computer program. Preventive maintenance activities onsite were prioritized in order of importance in the following manner: safety and licensing related, quality and production related, and support related. The safety and licensing priorities were the highest priority and ensure compliance with applicable radiological, criticality and industrial safety requirements, as well as regulatory and license requirements. The quality and production priorities deal with product and production issues. Finally, support priorities deal with operation of non-production and non-safety related equipment. The inspectors queried the computer database with licensee staff and noted no backlog of maintenance activities for safety and licensing related equipment in use. The licensee was in the process of removing equipment from the database used in conjunction with Line 1 in the UO2 building, l which was being dismantled and was no longer operable. The inspectors also l reviewed preventative maintenance records for Lines 1 and 2 of the DCF. The i inspectors noted that all the applicable semiannual preventive maintenance for Lines 1 and 2 in DCF were completed. The inspectors noted no concerns with the i

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preventive maintenance program implementation and noted that plant staff were knowledgeable of the computerized maintenance database.

A subcategory of preventive maintenance was delineated and referred to as instrument repetitive maintenance (IRM). Instrument repetitive maintenance program specifically defines the periodic inspection and calibration of instruments used to monitor and control equipment and processes in the preventive maintenance program. The inspectors specifically reviewed the preventive maintenance program for the nuclear criticality accident alarm systems onsite. Nuclear criticality accident i

alarms were required to be calibrated annually onsite. The inspectors reviewed Calibration Procedure 300. Revision 1, and the associated IRM data sheet. The inspectors noted that the calibration steps in Procedure 300, Revision 1, sequentially matched the corresponding steps in the IRM data sheet. The inspectors verified that all criticality accident alarms in use onsite were within the required annual calibration frequency. A review of randomly selected calibration records for the criticality accident alarms revealed that the calibrations reviewed were completed as required by Procedure 300. The inspectors also reviewed and walked down the installations and locations of criticality accident alarm instrumentation and determined the placement of detectors was consistent with Sections 4.1.7 and 10.6 of the License Conditions and Safety Demonstration, respectively,

c. Conclusions The licensee adequately implemented a preventive maintenance program for safety related equipment. Overall the program was effective, as demonstrated by no backlog for preventive maintenance of safety related equipment. No issues were identified with the instrument repetitive maintenance program for the criticality accident alarm system.

2.2 Observation of Onaoina Maintenance Activities

a. Inspection Scope (88025)

The inspectors observed ongoing maintenance activities associated with the Line 1 ion exchange resin columns and the calibration of level probes for cylinder washing activities. The inspection consisted of the observation of ongoing activities, reviews of applicable procedures and work instructions, and interviews with maintenance and operations staff.

b. Observations and Findinas The Line 1 ion exchange resin columns were scheduled to have preventive l maintenance conducted on the column flanges and seals. Although the columns l were no longer in active use, the licensee was planning to replace the seals in order

! to use the columns for other processes within the UO2 Building. The inspectors I observed the pre-job start up and noted that the materials and equipment, as well as the appropriate protective clothing were utilized for this evolution, as required by Procedure EMF-P66,1050, " Changing of lon Exchange Resins." Appropriate 1

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nuclear criticality safety controls were also implemented during the work evolution as required by the work sequence plan for downloading resin from the ion exchange columns.

As the resin downloading section of the procedure was started, maintenance and operations staff noted that the resin did not flow out of the ion exchange column as expected. Operations and maintenance staff appropriately stopped work and discussed the issue with operations and maintenance management. Operations management, in consultation with the process engineer, determined that the ion exchange resin had probably settled at the bottom of the column, because the columns had not been used for the past five months. Operations management determined that a procedure needed to be developed to address flushing the ion exchange resin in the column. Operations and maintenance staff were then directed to place the column into the original configuration and stop work on this activity. The columns were placed into the original configuration with no anomalies and the inspectors noted effective comrnunications among engineering, operations and maintenance staff during the entire evolution.

During the course of the inspection, the inspectors also observed maintenance activities associated with Tanks 246A and B, utilized for the cylinder washing station in the UO2building. The inspectors noted that the personal protective equipment specified in the radiation job permit for these maintenance activities was used by maintenance staff during work activities. The inspectors observed the in-place calibration activities associated with the level probes for Tanks 246A and B. The level probes in the tanks provide a criticality safety function as defined in the criticality safety analyses, by monitoring the level of solution within the tanks.

Calibration Procedure 154 in conjunction with the instrument repetitive maintenance data sheet were utilized to perform the calibration. The inspectors verified that measuring and test equipment used during the calibration was within the required calibration frequency. Maintenance staff perfornled the work on the level probes in accordance with Section 7.0 of Procedure 154. The inspectors noted that maintenance staff adhered to the procedure as written, and finalinstrument readings were verified to be within the allowable tolerance specified in the instrument repetitive maintenance data sheet.

c. Conclusions The inspectors concluded that the observed maintenance activities were conducted in accordance with approved procedures and radiation safety policies. During the ion exchange column resin removal, maintenance and operations staff demonstrated the ability to stop work activities when the job scope was beyond the applicability of the approved procedure. The level probe calibration was conducted in accordance with the work order and calibration procedure, and no concerns were identified by the inspectors.

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8-3 Transportation of Radioactive Materials 3.1 Radioactive Materials Packaaina. Labelina. Storace'and Maintenance

a. Inspection Scope (86740)

The inspectors reviewed the packaging, labeling and storage of containers prior to shipment, and the maintenance and rework of containers being pedormed. The l inspection consisted of procedural reviews, interviews and observation of work being pedormed to implement the requirements of 10 CFR Part 71 and the Siemens Power Corporation (SPC) license,

b. Observations and Findinas The packaging and labeling of the nuclear materials was performed during the week.

No nuclear materials were received or shipped during the inspection week. The l inspectors observed the packaging and labeling of fuel pellets in the Model ANF-250 '

containers. The licensee also demonstrated the packaging of UO2 powder in the Model NT-IX containers.

The inspectors observed the refurbishment of the Model 51032-1 containers for fuel I assemblies in the Shipping Container Refurbishing Facility. The inspectors observed the Model SP-1 fuel assembly container and the Model ANF-250 pellet and powder container rework program to bring the containers into compliance with  !

certificate of compliance design specifications. The storage and markings of these and other containers in the open bay areas was inspected.

c. Conclusions The packaging, rework and storage of the transportation containers was performed and documented according to procedures.

3.2 Ouality Assurance Procram for Transoortation of Shiocina Packaaes

a. inspection Scope (86740)

The inspectors reviewed the licensee's quality assurance (QA) program and licensee audits to determine if the licensee was effectively implementing the requirements of 10 CFR Part 71. The inspection consisted of interviews with quality assurance staff, review of the program requirements and a review of the audits performed. The

inspectors reviewed and discussed the interacting roles of the Traffic and l Warehouse, Traffic and Logistics, Quality Engineering, inspection Services and Radiation Protection groups that have responsibilities in the transportation of radioactive materials at SPC.

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b. Observations and Findinos Annual audits and required reports to regulatory agencies were reviewed.

Procedure EMF-30, (Revision 5), Safety Manual, Chapter 5, " Radioactive Material Shipping Standard," requires annual audits of radioactive material shipments to be performed by the Regulatory Compliance organization. The inspectors reviewed these audits dated November 6,1997, and January 8,1998, documenting findings, observations and comments. Procedure EMF-30 requires reports to the NRC per the requirements of 10 CFR 71.95(c). The inspectors reviewed the report of non-compliance to the NRC dated March 25,1998.

Procedure EMF-439," Quality Assurance Program for Nuclear Fuel Shipping Containers," contains the requirements of the licensee's NRC-approved QA program based on the requirements of Subpart H to 10 CFR Part 71. The inspectors reviewed SPC QA Audit No. 97:19 which was conducted by the licensee December 8-12,1997. The prior annual audits dating to 1995 were also reviewed.

The inspectors noted that the specific issues identified were addressed, but an investigation of the root causes was not performed to determine if other procedures or equipment might have similar issues. The inspectors' discussions with Quality and Regulatory Affairs staff indicate that this issue is recognized as a result of NRC Inspection Report No. 71-0003/98-203, dated June 2,1998 and Confirmatory Action Letter No. NMSS 98-8-002 dated March 17,1998, and is being addressed in response to these references.

The inspectors reviewed an action plan developed by Quality Assurance to assure compliance with 10 CFR Part 71. The plan addressed each requirement in 10 CFR Part 71 to assure each item is tracked.

c. Conclusions The required audits were performed and issues addressed. The inspectors' concerns about investigating and determining root causes of audit items was discussed with the quality assurance personnel and at the exit meeting. The quality assurance program was undergoing a program upgrade in response to a prior NRC Confirmatory Action Letter dated March 17,1998, due to previously identified concerns. The results of the program upgrade will be reviewed during future inspections.

4 Monthly Health and Safety Council The inspectors observed the monthly meeting of the Health and Safety Council.

This meeting is required by Part 1, Chapter 2, Section 2.3.1 of the License l

Conditions. Several presentations were made including the Council Safety Inspection, Monthly injury Report, Environmental issues, Notification to Regulatory Agencies, incident investigation Boards, Industrial Hygiene, Radiological Safety and Criticality Safety. The meeting was well attended, concise and timely.

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5 Emergency Preparedness Meeting The inspectors observed a meeting of the SPC, Stafe of Washington, Franklin County and Benton County emergency preparedness personnel. The meeting was conducted to discuss notifications and classifications of emergency events to assure that emergency conditions are responded to in a timely and effective manner. The groups came to an agreement on their issues and will provide further program clarifications to assure all personnel fully understand their interactions and responsibilities during emergency drills or events.

l 6 Followup 92702 6.1 Violation NIO) 70-1257/9803-01: Failure to follow procedures for segregation of hazardous waste and fuel rod downloading. A reply to the Notice of Violation was received on August 17,1998. A followup inspection on the corrective actions taken will be made during the next onsite inspection.

7 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on August 14,1998. The facility staff acknowledged the findings presented. The licensee did not identify any of the information discussed at the meeting as proprietary.

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I ATTACHMENT 1

SUPPLEMENTAL INSPECTION INFORMATION  !

PARTIAL LIST OF PERSONS CONTACTED l I

Licensee l

D. A. Adkisson, Manager, Quality Engineering, Quality and Regulatory Affairs

• B. F. Bentley, Manager, Plant Operations R. K. Burklin, Health Physicist M. A. Conway, Traffic and Warehousing Operations J. B. Edgar, Senior Engineer, Licensing B. N. Femreite, Vice President, Manufacturing

• H. C. Ford, Traffic and Warehousing Operations K. L. Ford, Manager, inspection Services, Quality and Regulatory Affairs

• E. L. Foster, Supervisor, Radiological Safety M. A. Hendrickson, Supervisor, Rod Fabrication Operations

• W. G. Keith, Manager, Plant Engineering M. A. Law, Manager, Analytical Services, Quality and Regulatory Affairs

• L J. Maas, Manager, Regulatory Compliance

• G. A. McGehee, Criticality Safety

• M. R. O'Neill, Manager, Maintenance Engineering R. D. Norman, General Supervisor, Traffic and Warehousing Operations J. H. Phillips, General Supervisor, Chemical Operations L. C. Phillips, Traffic and Logistics J. B. Perryman, Environmental

• T. C. Probasco, Manager, Safety L. G. Stephens, Supervisor, Plant Support Operations

• R. E. Vaughan, Manager, Safety, Security and Licensing

• Denotes present at exit meeting August 14,1998 I INSPECTION PROCEDUR$S USED Tl 2600/003 Operational Safety Review 88025 Maintenance / Surveillance 86740 Transportation 92702 Followup Violations /Dev.

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ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed  !

70-1257/9803-01 VIO failure to follow procedures for segregation of !

hazardous waste and fuel rod downloading l

l LIST OF ACRONYMS USED l ANSI American National Standards institute CFR Code of Federal Regulations DCF Dry Conversion facility ,

IRM instrument repetitive maintenance '

LUR Lagoon Uranium Recovery NRC Nuclear Regulatory Commission PDR Public Document Room OA quality assurance l SPC Siemens Power Corporation SPF Solids Processing facility U-235 uranium-235 .

UF, uranium hexafluoride UO, uranium oxide VIO violation