ML20199B405
| ML20199B405 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 01/06/1998 |
| From: | Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20199B401 | List: |
| References | |
| 70-1113-97-08, 70-1113-97-8, NUDOCS 9801280269 | |
| Download: ML20199B405 (13) | |
Text
_____ _ __ _ ___ ____ _ _____ ____ - - -
U.S. NUCLEAR REGULATORY COMMISSION REGION 11 Docket No.:
70-1113 License No.:
SNM 1097 l
Report No.:
70-1113/97-08 Licensee:
General Electric Company Wilmington, NC 28402 Facility Name:
Nuclear Energy Production Dates:
December 8 12, 1997 Inspectors:
D. Ayres, Senior Fuel Facility Inspector Approved by:
E. J. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety 1
9001280269 900106 PDR ADOCK 07001113 C
PDR Enclosure
Executive Summary General Electric Nuclear Energy Production NRC Inspection Report 70 1113/97-08 The primary focus of this routine unannounced inspection was the evaluation of the licensee's conduct of plant operations and maintenance. The report covered a one week period and included the results of inspection efforts of one regional fuel facility inspector.
Plant Ooerations The licensee's conduct of o)erations was being performed according to e
area safety requirements.
Passive engineered controls for assuring proper control of uranium enrichments were in place and functional (Section 2.a).
The licensee responded promptly to safety related events and incidents.
e 3roperly characterized them, and took appropriate corrective actions.
ollow up of recommendations made by corrective action implementation teams need to be tracked to closure. One Non Cited Violation was noted for deviations from the approved configuration control system, the final corrr-tive actions of which will be tracked as Inspector Followup Item 97 08-02 (Section 2.b).
Maintenance / Surveillance The licensee's system for controlling maintenance of safety controls e
in the Dry Conversion Process areas was adequate for assuring the operability of Automatic Engineered Controls.
Maintenance was-being
-performed as identified by the Integrated Safety Analysis through the use of adequate work control procedures.-and included appropriate post-maintenance functional testing (Section 3.a).
The licensee was adequately controlling work authorizations for e
maintenance activities.
The licensee took quick action to identify and correct an occurrence where the system for controlling _ work authorizations was bypassed (Section 3.b).
Attachment:
Persons Contacted and Exit Interview List of items Opened. Closed, and Discussed list of Acronyms
4 REPORT DETAILS 1.
Summary of Plant Status This report covered a one week period.
Plant activities included normal powder production in the Ammonium 01uranate (ADU) facility, routine pellet and assembly production, and normal uranium recover The Dry Conversion Process (DCP) was operating with line #y operations.
enriched powder, line #2 producing natural powder, and line # producing 1
3 was undergoing construction / qualification. The new gadolinia shop and dry recycle system associated with DCP were being prepared for initial startup.
2.
Plant Ooerations (88020) (03) a.
Conduct of Ooerations (03.01)
(1)
Insoection Scoce The inspector conducted a facility tour to observe conduct of operations, and to confirm that material storage, process operations. and process related activities were being performed in accordance with written safety requirements.
(2)
Observations and Findinas The inspector observed operations in the ADU process area, the pellet production area, the gadolinia shop,The inspector the DCP facility, and the Uranium Recovery (UR) area.
compared the operations in each of these areas with the requirements listed in the Nuclear Safety Release /
Requirements (NSR/Rs) for selected areas. The inspector observed )ressure readings on ventilation systems and HEPA filters tiroughout the facilities.
The. inspector found that all operating systems were within the required pressure i
ranges.
The inspector observed the storage of Special Nuclear Material (SNM) throughout the facilities.
These observations included storage of UF, cylinders. 3 gallon and 5 gallon powder cans. pellet trays, and DCP facility bulk powder containers. The inspector found that all observed SNM storage was being conducted in accordance with local safety requirements.
The license'e identified that an annular tank in the UR area had been slowly leaking uranium waste solution into a diked area.- and that-insulation had been found inserted into the
=
annular space between the solution reservoir and the borated stainless steel plate used for neutron absorption.
The licensee identified that this was a concern due to the potential for accumulations of SNM immediately adjacent to the favorable geometry solution reservoir inside the neutron
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i 0'
I absorbing barrier. The inspector observed that the licensee removed the insulation material, found that it did not contain significant quantities of SNM, and found that the licensee-verified that all other vessels of similar design did not have insulation (or other foreign materials) lodged between the solution reservoir and the neutron absorber.
The inspector found that the licensee reacted to an unexpected potential safety problem, and repaired the leaking annuler tank in an expeditious but careful manner in order to assure nuclear and radiological safety.
(3)
Conclusions The licensee's conduct of operations was being performed according to area safety requirements.
Passive engineered controls for assurir<g proper control of SNH enrichments were
?
in olace and functional.
The licensea reacted well to an une'pected potential safety problem.
x
- b, Review of Previous Events (03.07)
(1)
Insoection Scoce Operational events occurring since the last inspection were reviewed for adequacy of licensee responses.
(2)-
Observations and Findinos (a)
Uranium Release from HF Recovers Buildino The inspector reviewed the licensee findings-
.i associated vith the event involving a radiological release from the DCP HF Recovery Building.
This event was reported to the NRC Operations Center and was documented as Event Notice No. 32874. The inspector reviewed the Unusual Incidens Report (VIR) generated by the licensee and fGJnd that two higher level investigations were performed as a result of the VIR*s findings. One of these investigations focused on the actual release mechanism of contamination to the environment. The other investigation focused on the development of the source term that led to the release.
The inspector found that-the two investigations uncovered the root causes of the event and proposed short and long term corrective actions-The-inspector found that the short term corrective actions were completed prior to restart of the process. The inspector found that the short term corrective actions included modifications-to procedural and engineered controls, and a corresponding license-amendment
.-..a
3 submittal: cvaluation of 3rocess dynamics to identif maximum credib 4 uranium ioldups and stack releases:y updating safe'. oasis documentation; and review of lessons learneo with entire DCP team. The inspector found that the long term corrective actions included evaluations of operating philosophy for imp.oved equipment performance: improved operator training'and communication tools: and improved control room ergonomics and information flow.
The inspector observed that the evaluation of t.'ie maximum potential stack release determined that a much larger release may be possible due to common cau:6 failures of safety controls.
The inspector observed that the evaluation report estimated the probability of such a common cause failure to be roughly 2% per month, but that this probability could be reduced by increasing the frequency and rigo. of valve inspections and repair. - The inspector found that the licensee was developing a valve testing precedure to effectively reduce the probability of common cause failures. The inspector also observed that a more detailed investigation of common failure mechanisms was recommended in the evaluation report.
The inspector found that the licensee's summary of corrective actions showed that the evaluation of the maximum potential stack release had been completed.
However, no new items were added to the summary as a-result of the evaluation report recommendations.- The inspector found that followup corrective actions needed te be tracked until closed.--The licensee indicated that the follow up actions would be tracked end completed in a timely manner.
(b)
Liauid Hydrocen Tank leak The inspector reviewed the release of hydrogen from a pressure control system at a liquid hydrogen tank.
The inspector found that the hydrogen release occurred inside the gas vendor's equipment boundary and was thus well removed f.*om SNM access areas.
The
. inspector found that the licensee reacted to the situation properly by shutting down the hydrogen delivery system and notifying.the-gas vendor of the need for repairs.
(c)
Unusual incident Recorts The inspector reviewed the remaining UIRs (about 25) opened since July 1997. Although all but one of these UIRs did not lead to higher level investigations. the inspector found that they were appropriately evaluated
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for seriousness, urgency, and potential growth into i
larger problems.
The inspector found that each VIR adequately addressed the causes and corrective actions taken.
(d)
Unanalyzed Pellet bats The inspector reviewed a licensee internal memorandum i
declaring a Licensee Identified Violation (LIV) for the purchase of pellet boats that were of an alternate 4
design that was not ap3 roved through the configuration-i management process.
T1e alternate boat design was discovered whe tare weights of the boats were rejected by the production s out of the allowable range. ystem software for beingA licens ofthetareweightrejectionsledtothediscoverycf the alternate boat design that was added to the part drawing in January 1994. The altered design was a 4
concern since-it had not been analyzed for its effects-oi, the nuclear safety of the pellet >roduction process.
The inspector found that t11s item was i
identified to NRC by the licensee.-was not expected to
]
be prevented by corrective actions implemented in the past two years, would be corrected within a reasonable time by a specific commitment of corrective action.
and was not a willful violation, Therefore, this licensee identified violation was not cited because criteria specified in Section Vll B of the 18C Enforcement Policy were satisfied and will 3e considered Non Cited Violation (NCV) 70-1113/
97 08 01. Additionally, a separate UIR was to be generated to identify the near term and-long term corrective actions, the completion of which will be tracked as Inspector Followup Item (IFI) 70 1113/
97 08 02.
(3)
Conclusions The licensee responded prompt?Y to safety related events and incidents, properly characteri' zed them.. and took appropriate corrective actions.
Follow up of recomendations made by corrective action implementation teams need to be tracked to closure. One Licensee-Identified Violation (NCV 97-08 01) was noted for deviations from the approved configuration control system, the final corrective actions of which will be tracked as IFI 97-08 02.
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c.
Follow-uo on Previousiv Identified Issues (1)
Insoection Scoce The progress of corrective actions for five previously identified Inspector Follow-up Items (IFIs) were reviewed for possible closure.
(2)
Observations and Findinas The inspector reviewed the corrective actions taken in response to IFI 96-11-01 concerning inoperable and inaudible criticality horns.
Previously inspected corrective actions included re) lacing deteriorated equiament and audibility testing. T1e inspector found that tie licensee had developed new drawings of the criticality horn circuits to more easily identify which horns would be affected by a loop failure. The inspector found that the new drawings were placed in the licensee's configuration control system to prevent undocumented changes to the system.
The inspector alsu observed that placards had been affixed near eye level below each horn so that any horn found inoperable would be easily identified. The inspector found that these improvements to the criticality horn system was sufficient to close IFI 96-11-01.
The inspector reviewed licensee actions taken '
sponse to IFI 97-07-01 for improving the identification G.ntrances and prevention of unauthorized or accidental access to controlled areas. This IFI was opened when inspe: tors found doorways to controlled areas that were easily accessible from uncontrolled areas without passing through change rooms.
The inspector found that the licensee took action to remove the door handles from the uncontrolled side of the doors of primary concern so that they could only be opened from within the controlled area for emergency egress. The inspector also found that door alarms with stop signs were installed on other doorways that led into controlled areas where it was deemed necessary to leave the outside door handles in place for emergency response access.
The inspector found that these actions were adequate to close IFI 97-07-01.
The inspector reviewed a license amendment submittal made to NRC in response to IFI 97-07-03. The license amendment attemated to resolve discrepancies between plant practices and t1e license application concerning not requiring contamination surveys at certain step off pads. The inspector found that the amendment yplication was still under review by NRC licensing staff and was thus not yet approved. Therefore, the inspector found that the discrepancy still existed and IFI 97-07-03 remained open.
6 The inspector reviewed the licensee's corrective actions resulting fr om a root cause investigation concerning the scalding of a maintenance worker in the uranium recovery area. The inspector found that corrective actions included additional training of the maintenance workers on the equipment involved and an improved operational procedure.
The inspector observed that a corrective action remained open for testing a 3ressure relief device on one of the l
pumps involved in tie incident.
However, the inspector found that this device was an experimental enhancement to the system and that the corrective actions already taken were adequate to 3revent recurrence. Therefore, the inspector found t1at IFI 97-07-04 could be considered closed.
The inspector reviewed the licensee's corrective actions resulting from a LIV concerning a temporary modification to a ventilation system in the DCP. As stated in the LIV. a maintenance worker had modified the DCP ventilation system by installing a temporary flexible line to capture the small amount of UF, expected to be released upon disconnecting of a process line. The modification was performed without approval through the configuration management system and without c Radiation Work Permit.
The licensee's r
investigation results and corrective actions were being tracked as IFI 97-07-06.
The inspector observed that adjustments were made to tha licensee's maintenance control and configuration management procedures, and that a portable ventilation unit was fabricated and in place for the future needs of the DCP. The inspector found that these corrective actions and the retraining of the maintenance worker were adequate responses. Therefore. the inspector found that IFI 97-07-06 could be considered closed.
(3)
Conclusions The licensee's implementation of corrective actions in response to previously identified issues were adequate in four of the five issues reviewed, and these four IFIs can be closed.
The determination of the adequacy of the remaining issue (IFI 97-07-03) was pending the completion of the NRC review of the associated license amendment request.
~
7 3.
Maintenance / Surveillance (88025)(F11 a.
Conduct of Maintenance (F1.011 Work Control Procedures (F1.02)
Surveillance Testina (F1.06)
(1)
Insoection Scooe i
The maintenance database for DCP safety controls was reviewed to verify that maintenance was being conducted via work control procedures including post-maintenance surveillance testing, lysis (ISA).
on required items identified.in the Integrated Safety Ana (2)
Observations and Findinos The inspector reviewed the ISA for the DCP and chose a sampling of the Automatic Engineered Controls (AECs) used.in line #1 of the process to be reviewed. The sampling consisted of a wide variety of instruments and sensors.to cover the measurement and control of most of the process L
variable types important to safety. The insp2ctor observed the licensee's Maintenance Planning and Control (MPAC) i database and found that each of the items chosen for the sample was included therein.
The ins)ector also observed that for each safety-related AEC in t1e sample, the MPAC system included item descriptions locations, a record of maintenance activities, spare parts lists. instructions for conducting routine and preventive maintenance (R&PM), a list of the next twelve scheduled R&PM dates, and instructions l
for post-maintenance testing (PMT).
The inspector found that the frequencies established for R&PM (ranging from monthly to annually) was adequate and 2
that all maintenance on AECs had been performed as scheduled or prior to being placed into operation. -The inspector also found that the instructions provided to the maintenance workers were adequate to locate the proper AEC device on the production floor and to aerform the required R&PM. The inspector observed that 3MT was performed on each AEC by issuance of a work order separate from the original R&PM work order. The inspector found that in all cases. PMT was completed before returning the safety control to service.
(3)
Conclusions The licensee's system for controlling maintenance of safety controls in the DCP areas was adequate for assuring the operability of AECs. Maintenance was being performed as identified by the ISA through the use of adequate work control procedures. and included appropriate post-maintenance functional testing.
4 1
8 b,
Work Control Authorizations (F1.03)
(1)
Insoection Scoce-Changes to safety control systems were reviewed to verify they are specifically approved under the configuration management program requirements.
l (2)
Observations and Findinas The inspector observed selected changes made to the DCP safety controls as part of the corrective actions for the HF Building release discussed in section 2(b) of this report.
The inspector found that in each case, changes were initiated by completing a Change Request form and routing it through the proper approval circuit. The inspector found that the change requests were reviewed by appropriate licensee management. The inspector also found that the potential need for changes to process instructions and documentation (NSR/Rs. Criticality Safety Evaluations.
Operating Procedures. Piping and Instrumentation Giagrams, etc.)
_ ere bei,19 adequately reviewed by licensee management w
per the Configuration Management Control procedure requirements.
In s changes in the DCP pite of the adequacy-of '.hese recent f
the inspector noted that the LIV discussed in section 2(c).of this report was an incident involving the unauthorized change to a process safety system to facilitate maintenance activities.
(3)
Conclusions The licensee was adequately controlling work authorizations for maintenance activities. The licensee took quick action
-to identify and correct the occurrence where the system-for-controlling work authorizations was bypassed.
4, Exit Interview The inspection scope and results were summarized on December 12. 1997.
with those persons indicated in the Attachment. The inspector described the areas inspected and discussed the inspection results including the non-cited violation, and the likely informational content of the inspection report with regard to documents and/or processes reviewed during the inspection. Although proprietary documents and processes were occasionally reviewed during this inspection. the proprietary nature of'these documents or processes has been deleted from this report. Dissenting comments were not received from the licensee.
l
ATTACHMENT Licensee
- R. Bragg. Team Leader. Powder Prepcration & Packaging
- D. Brown. Team Leader. Environmental Programs
- D. Dowker. Team Leader. Fuel Support
- T. Flaherty Manager. Dry Conversion Project
- R. Foleck. Senior Licensing Specialist
- R. Keenan Manager. Site Security and Emergency Preparedness
- J. Kline. Powder Production Line Manager
- A. Mabry. Program Manager Radiation Safety Engineering
- S. Murray. Team Leader. Chemical Conversion
- W. Ogden. Facilities Manager
- L. Paulson, Manager. Nuclear Safety
- J. Reyes. URU Area Coordinator
- 8. Robinson Principal Nuclear Safety Engineer
- E. Rouse. Radiation Protection
- H Shaver. Nuclear Safety Engineer
- G. Smith. Team Leader. FM0 Maintenance
- S. Smith, Radiation Safety Monitor
- H. Stricklrr. Manager. Site Environmental. Health & Safety
- C. Tarrer. Leader. Configuration Management J
- D. Turner. Environmental Engineer
- C. Vaughan. Acting Manager. Facility Licensing
- P. Vescovi. Nuclear Safety Engineer
- C. Williams ADU Engineer Other licensee employees contacted included engineers, technicians, production staff security, and office personnel.
- Denotes those present at the exit meeting on December 12. 1997.
INSPECTION PROCEDURES USED IP 88020 Plant Operations IP 88025 Maintenance and Surveillance Testing LIST OF ITEMS OPENED. CLOSED, AND DISCUSSED Item Number Status Descriotion 70-1113/96-11-01 Closed IFI - Verify the completion of corrective actions in response to finding inoperable criticality horns.
2 70-1113/97-07-01 Closed IFI - Review improvements in identifying entrances to controlled areas.
70-1113/97-07 03 Open IFI - Review corrective actions to correct discrepancies betweea plant practices and License Application concerning step-off pads.
70-1113/97-07-04 Closed IFI - Review Taproot investigation findings and corrective actions concerning the scalding of a maintenance worker in Uranium Recovery.
70-1113/97-07-06 Closed IFI - Review licensee's investigation of the configuration management procedure violation involving r
a temporary modification to a
(
ventilation system in the DCP area.
70-1113/97-08-01 Closed NCV - Change made to fabrication drawing and subsequent procurement of pellet boats without proper approvals.
70-1113/97-08-02 Open IFI - Review and verify completion of corrective actions taken in response to NCV 97-08-01.
LIST OF ACRONYMS USED AEC Automatic Engineered Control ADU Ammonium Diuranate DCP Dry Conversion Process FM0 Fuel Manufacturing Operations GE General Electric HEPA High Efficiency Particulate Air IFI Inspector Follow-up Item IP Inspection Procedure LIV Licensee-Identified Violation MPAC Maintenance Planning and Control NCV Non-Cited Violation NSR/R Nuclear Safety Release / Requirement PMT Post-Maintenance Testing
3 SNM Special Nuclear Material UF Uranium Hexafluoride Ulk Unusual Incident Report URV Uranium Recovery Unit 1