ML20198Q202

Insp Rept 70-1201/97-205 on 971217.No Violations Noted.Major Areas Inspected:Receiving & Storage Vault Areas,Pellet Loading Room,Fuel Rod Processing Area & Fuel Bundle Assembly & Storage Areas

ML20198Q202
Person / Time
Site:	07001201
Issue date:	01/12/1998
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20198Q186	List: ML20198Q181 ML20198Q202
References
70-1201-97-205, NUDOCS 9801220368
Download: ML20198Q202 (9)

Text

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS f

t Docket No: 70 1201 s

License No: SNM 1168 Report No: 70 1201/97 205 .

1 License Holder: Framatome Cogema Fuels Location: Lynchburg Manufacturing Facility Lynchburg, Virginia Date: December 17,1997 Inspectors: Christopher Tripp, inspection Team Leader, NRC Headquarters Dennis Morey, inspector, NRC Headquarters .

I Approved By: Philip Ting, Chief Operations Branch, Division of Fuel Cycle Safety and Safeguards, NMSS Enclosure hD C PDR 01

i FRAMATOME COGEMA FUELS LYNCHBURG MANUFACTURING FACILITY NRC INSPECTION REPORT 70 1201/97 205 EXEC.UI. lye

SUMMARY

inkodWCliOD NRC conducted a routine unannounced nuclear criticality safety (NCS)inspe'ction of the Framatome Cogema Fuels' Lynchburg Manufacturing Facility (LMF) in Lynchburg, Virginia, on December 17,1997. The inspection was conducted by NRC Headquarters staff, using Inspection Procedure IP 88015, and focused on the following areas:

o Configuration Control for NCS e Operating Procedures

• CAAS Alarm Coverage o Follow up of Previous inspecting Findings As a result of this inspection, no violations or new open items were identifiod. Three of six open items from inspection Report 701201/07 202 were closed and three remain open.

Besulta e No immediate safety issues were identified during this inspection.

e Three of six open items from inspection Report 701201/97 202 have been closed.

• Cnticality safety postings have improved significantly, but there were cases where postings were out-of-date or confusing, which the licensee has committed to change.

e The conduct of safety audits has improved, but timeliness of corrective actions and unconfirmed findings conceming operability of safety equipment are potential areas of concern, o Guidance in postings on the use of water in fighting fires in moderation control areas is too general, and requires additior.al clarification by NCS.

Conclusl0D Overall compliance with criticality safety postings and procedures was adequate in the plant areas examined. Posthigs have improved since the previous nuclear criticality safety inspection, but there were still cases of inaccurate or confusing postings. Since the plant relies on these postings as the primary communication method for administrative controls, the maintenance of accurate postings is important to overall nuclear safety. The conduct of safety .

audits and NCS guidance concerning firefighting in moderation control areas continue to be areas needing improvement.

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, e REEDRT DETAILS 1.h PLANT ACTIVITIES'  ;

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The inspectors toured the fissile material areas in the LMF to determine whether the activities ,

were conducted safely and in accordance with license requirements, postings, and procedures.

The inspectors also reviewed enticality safety postings in the plant to determine whether cnticality safety requirements applicable to operations were contained in the postings.

i DAttfYall9ns and FindiDSR TM ineectors walked through the receiving and storage vault areas, the pellet loading room, the wel rod processing area, and the fuel bundle assembly and storage areas. The inspectors observed that engineered controls were functional and that administrative controls were properly implemented. Engineered controls consisted mostly of barriers to limit stacks of pellets and fuel rods to 4", and racks to control spacing of fuel bundles. The main administrative t controls were limits on stacking material and use of moderators.

The inspectors observed that nuclear criticality requirements were communicated to the operators primarily through postings rather than operating procedures. During NRC Inspection 97 202, the inspectors determined that licensee postings needed improvement, and the licensee committed to develop a procedure for plant postings and create and display adequate postings in the plant. The inspectors reviewed licensee procedure SL 1500, which controls postings, and reviewed the in-plant criticality safety postings to determirn the extent of the changes. The inspectors determined that a completely new type of posting had been developed, which contained criticality safety requirements for specific plant areas, rather than generic requirements as had been the previous practice. The administrative limits were segregated from other safety rules through the use of posted ' Criticality Safety Rules'. Other rules not related to criticality safety were on postings identified as

• Local Safety Rules." The inspectors observed that the postings were clear and adequate in most cases. However, the inspectors identified several thficiencies in the specific requirements contained in the postings, as follows:

• In the pellet storage vault and pellet loading room, a control for fissile bearing solutions was observed. The licensee is no longer authorized to handle fissile bearing solutions,

• In the fuel rod processing area, the postings required that containers are not stacked more than 6' high. This is not a criticality safety rule and did not belong on the posting,

• In the pellet storage vault, postings required that vault shelves be at least 9'11" apart.

This dimension is not a criticality safety requirement and cannot be easily altered.

'Section titles correspond to sections ofIP G015 3

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• In the fuel bundle shipping area, where fuel bundles are loaded into shipping containers, the postings required that loaded shipping containers be spaced at least 18" apart. T: 2  ;

licensee indicated that loaded containers are packed tightly in two layers during storage i The licensee stated that the rule was intended to apply to containers while they are i being loaded, and to the buno,es within. Although the shipping containers maintained spacing between bundles to 18" as an integral part of their design, as required, the administrative requirement was unclear.

Because the postings are the main method used to communicate nuclear enticality controls to the operators, it is important that they are clear, maintained up to-date, and posted in the proper location.

The licensee corrected the first three deficiencies by removing the requiremente, and committed to develop and implement clearer language to correct the fourth. The inspectors also noted that the posting concerning the alpha counting room was posted outside one of the two entrances to the room. The licensee committed to place the posting inside the room.

The inspectors reviewed audit NS 97-1, *First Semi-Annual Nuclear Safety Audit of LMF,* dated November 3,1997, as part of the follow up of previous inspection findings (see Section 5.0).

This audit contained a finding that the rule requiring fuel storage less than 6 feet from the floor was

• difficult to understand" and "needed to get fixed.* However, the posting was not changed until the inspectors pointed it out on their walk-through. The licensee stated that the temeliness of corrective action to this finding was within 30 days from the time the aud't was received by the Manager, Safety and Licensing. However, it took almost a month from the date of the audit to be received by the Manager, Safety and Licensing. Given the importance of the postings at this facility, the time required to resolve negative audit findings concerning posting clarity indicates a potential problem in the corrective action program.

The inspectors also noted a checklist requirement to verify that the sump pump in the bundle inspection pit functioned. The sump pump is designed to control the level of water in the inspection pit in the event of flooding, to maintain moderation control. The licensee indicated that there have been cases in which the inspection pit became partially flooded. The inspectors noted that the pump had been checked off as operable in the audit, even though ti. ore was a comment that the pump had not actually been seen and was assumed to be functional. The inspectors examined this pump and confirmed that it was operating, and so the safety significance of this finding is low.

Conclunkna Compliance with posted limits and administrative controls was adequate. The condition of engineered controls was adequate. The new licensee criticality safety posungs were adequate.

The postings represent considerable improvemens in that the criticality rules are separated from other rules and clearly identified. However, four e c /s of out-of-date or potentially confusing postings were found, that the licensee immediatt # Grrected when identified by inspectors.

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2.0 CONFIGURATION CONTROL FOR NCS Scnot The inspectors examined the configuration control program for NCS documentation, to ensure that the documents which establish the safety basis are up-to-date and consistent, revised and distnbuted according to a document control program, and reflect the as built condition of the plant.

Dhtt&AllonB_RndCndlDgl The inspectors examined procedure SL 1000, ' Preparation, Revision, and Control of Safety and Licensing Documents," Rev,1. This procedure covered document control of nuclear criticality safety documents, including Nuclear Criticality Safety Evaluations (NCSEs) and operating procedures. The inspectors verified that requirements existed for controlling distributed versions of documents through a document control voucher system. Reviews and approvals, including independent reviews, are controlled with Document Revision / Approval Records (Form SL 10001). The inspectors determined that the program was adequate to ensure configuration control of NCSEs operating procedures, and postings and maintain the safety basis of the plant.

Conclusions The procedures for revising, approving, and maintaining nuclear criticality safety documentation were found to be adequate to maintain the safety basis of the plant.

3.0 OPERATING PROCEDURES Scoon The inspectors reviewed the hcensee process for ensuring that criticality safety controls flow from analysis into procedures, postings, end/or employee training, for analysis of new operations and plant changes.

DhtetYAllong_and Findings The inspectors determined that controls were established by the licensee through a four-step process. When a new or changed process is proposed a pre-operational safety evaluation is performed. If fissile materialis involved in or affected by the process, a concurrence request is sent to criticality safety. A cnticality evaluation is performed and a summary sheet is prepared, listing the required controls. The list of controls is returned with the concurrence request and the controls are then incorporated into training or postings, as required. The licensee noted that procedures are not normally used to implement criticality safety controls. The inspectors noted that only two employees, the safety manager and the criticality engineer, were normally involved in the procesa No instances of failure to incorporate a criticality safety limit were observed.

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Geoclusians The licensee process for identifying criticality safety controls and ensuring that they are correctly implemented was found to be adequate. ~ t i

e 4.0 CRITICALITY ALARM MONITORING SYSTEM i 1 4 Gest i The inspectors reviewed the criticaldy alarm detector placement and operation to determine that j coverage was adequate. The inspectors also reviewed calibration records and functional test i

_ procedures to determine that adequate steps were taken to ensure that the system will pedorm if required.  ;

j Obaarvations and F!ndings l .

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. The licensee uses a gamma alarm system for criticality detection. Twelve Nel detectors are  ;

located throughout the plant and a two of twelve coincidence logic system is used to trip the  !

criticality alarm system. This means that any two of the detectors tripping or malfunctioning will  !

trigger the criticality alarm system. ANSI /ANS 8.3,6ection 5.4, requires that component failure  !

l shall not produce an alarm. The licensee has committed to correcting the alarm logic so that  !

dual failure will not produce an alarm. The inspectors determined that all areas of the plant were i covered by at least two detectors.

The inspectors reviewed the criticality alarm calibration records and determined that the alarms f were calibrated in accordance with written procedure RP-018, ' Calibration and Maintenance of  :

CAS,' Rev. 2, dated Decomuer 13,1994. The alarms are calibrated annually with a Cs-137 i source in accordance with the licensee procedure, in addition to quarterly source checks, the j

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alarm logic and homs are checked annually. Although the entire system is checked annually,  !

no annual evacuation drill is conducted for criticality alarms, as required by Section 7.3 of  :

ANSI /ANS-8.3. The licensee has committed to evaluate the feasibility of conducting annual i evacuation drills, which should be announced in advance in accordance with the standard.  !

l Gericlualons t

The Iicensee criticality alarm system coverage and maintenance is adequate. The licensee 3

needc to incorporate the criticality alarm system into the annual emergency evacuation drill 1 ' schedule. i 5.0 FOLLOW UP OF OPEN ITEMS - '

i IFl 701201/97 202 01 This item concerns a certificate of compliance for the borated stainless steel (BSS) plates in the

. fuel assembly inspection pit; ;The licensee was unable to obtain certification from the )

1 manufacturer and is currently preparing to test a sample from one of the plates! The results of  ;

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this test are expected to be available by the end of March 1998. IFl 701201/97 702 01 remains open.

IFl 701201/97 202-02 This stem concerns development of a procedure for performing, reviewing, and approving criticahty safety evaluations. A draft procedure was in review and is expected to be approved by the end of January 1998. IFl 701201/97 202 02 remains open.

IFl 701201/97 202-03 This item concerns the adequacy of criticality safety postings in the plant. The licensee has completely revised all criticality safety post n(,a in the plant. The inspectors reviewed the new t postings and determined that they were ad.iquate. IFl 701201/97-202-03 is now closed.

IFl 701201/97 202-04 This item concerns formal documentation that the safety basis is completed prior to starting up a new or modified process. The inspectors reviewed procedure SL 1170," Safety Review Board,' Rev. O, and confirmed that this requirement has been implemented as an

• Operational Change Request"(OCR). The process requires three different forms (SL 11701, SL-1170 2, and SL-1170-3) to be completed prior to start up, which contain pre-operational checklists to ensure that the modifications are reviewed by appropriate safety organizations. This also requires that operators are retrained on modified postings srid procedures. The operation cannot be started until form SL 1170 3 is released by the Safety Review Board (SRB)

Chairman. The inspectors reviewed several examples of the completed SL 1170 3 and confirmed that this process was followed. IFl 701201/97 202-04 is now closed.

IFl 701201/97 202 05 This item concerns incorporation of license requirements into safety audit procedures.

The inspectors examined procedure SL-1150, ' Health and Safety Audits,' Rev. O, to ensure that the requirements of License Section 2.7,' Audits and inspections

• were satisfied. Procedure SL 1150 steps 6.2.1 - 6.2.4 adequately address the four required elements for semiannual audits. Therefore, IF 701201/97 202-05 is now closed.

IFl 701201/97 202-06 This item concerns the interface between emergency response functions during firefighting.

The inspectors observed a sign over the entrance to the bundle assembly area that required consultation with a criticality safety specialist prior to using water in firefighting activities, and required the use of only one fire hose. The licensee has briefed offsite fire responders on these requirements. As discussea in Inspection Report 701201/97 202, there may be cases in which the generallimit of one fire hose is not sufficient to ensure NCS, Since additional guidance has been requested but not received from NCS, and since there is no formal writtan agreement between the plant and offsite fire support, IFl 701201/97-202-00 remains open.

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.- i There has 9 adequate progress in three of the six open items from the previous inspection.

- Hopver,.t ,- unfirmation of equipment operability when the equipment is required for nuclear 3

- enticaldy safely, and the detail of current guidance on use of water in fighting fires in moderation  !

control areas, are areas needing further_ improvement. i i

6.0 Exit Meeting I An exit meeting was held between NRC Headquarters staff and plan' management on i December 17,1997. No classified or proprietary information was discussed.  ;

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ITEMS OPENED,GLOSED&fLQ13CDS$ED Closed 70 1201/S7 202-03 IFl Adequacy of criticality safety postings.

70 1201/97 202-04 IFl Documentation of NCS safety basis prior to start-up.

70 1201/97 202-05 IFl Revision of audit procedure to reflect license requiremente.

Discussed 70 1201/97 202-01 IFl Certificate of compliance for BSS plates ir. inspection pit.

70-1201/97 202 02 IFl Procedure for performing criticality safety evaluations.

70 1201/97 202-06 IFl Emergency procedures for response interfacos.

PARTIAL LIST OF PERSONS CONTACTED G. Elliott Manager, Safety and Licensing D. Gordon Senior Health Physicist J. Matheson Plant Manager, LMF A. McKinn Manager, Quality / Health / Safety B. Palmer NCS Spacialist ACRONYMS USED DSS Borsted Stainless Steel CAAS Criticality Accident Alarm System LMF Lynchburg Manufacturing Facility NCS Nuclear Criticality Safety NCSE Nuclear Criticality Safety Evaluation OCR Operational Change Request SRB Safety Review Board 9