ML20199D507

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Enforcement Conference Rept 70-1151/97-207 on 971029.Areas Discussed:Seven Violations Noted in Rept 70-1151/97-205
ML20199D507
Person / Time
Site: Westinghouse
Issue date: 11/13/1997
From:
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20199D504 List:
References
70-1151-97-205, 70-1151-97-207, EA-97-244, NUDOCS 9711200351
Download: ML20199D507 (52)
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Text

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4 U.S. NUCLEAR REGULATORY COMMISSION

' OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS -

E A N o.- 97-244 Report No. 70-1151/97-207 License No. SNM-1107 00cket No. 70-1151 Licensee: Westinghouse Electric Corporation Commercial Nuclear Fuel Division Columbia, SC 29250 Pre-Decisional Enforcement Conference Conducted at: Rockville, MD Pre-Decisional Enforcement Conference Conducted on: October 29,1997.

Prepared by: W. Troskoski, Senior Chemical Engineer +

Approved t y: Philip Ting, Chief Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS 4

Enclosure 1 i-9711200351 971113 P PDR ADOCK 07001151c -

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O EXECUTIVELEUJMIARY Westinghouse Electric Corporation Predecisional Enforcement Conference Report I

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l On October 29,1997, a predecisional enforcement conference was held at NRC Headquarters, i I

Rockville, Maryland, to discuss seven apparent violations identified in Inspection Report No.

70-1151/97-205. The conference provided an opportunity for Westinghouse Commercial Nuclear Fuel Division to discuss the seven apparent violations and to provide information concerning the corrective and preventive actions. The licensee acknowicdged five of the violations, portions of one violation and denied one violation. The licensee described the corrective actions undertaken to correct the items of non-compliance, application of the lessons leamed to prevent similar violations from occurring in the future, and committed to provide a finalized plan and scheduls for lasting corrective actions by December 15,1997 (see Enclosure 2).

In the opening remarks, the Director of the Division of Fuel Cycle Safety ard Safeguards stated the reasons for the predecisional enforcement conference as it related to the two losses of volume / geometry criticality safety control events of June 23 and August 25,1997. The Director explained that this meeting would provide Westinghouse Commercial Nuclear Fuel Division the opportunity to discuss the events and apparent violations identified during the August 25-29, 1997, safety insocction; to acknowledge or deny the apparent violations; and to identify the root causes and corrective actions. The Director indicated that the NRC was concerned that plant as-exists field conditions did not match design documents, nuclear criticality safety (NCS) implementing procedures and policies did not properly address a number of NCS activities, and improvements in communication between the licensee and NRC were still needed.

The NRC Enforcement Coordinator summarized the NRC's Enforcement Policy concerning the two events. The discussion included the purpose of the predecisional enforcement conference and the enforcement process before the NRC makes a final enforcement decision.

The Chief of the Operations Branch discussed the seven apparent violations identified in the inspection report which included:

1) The inadequate incident investigation of both events, including the failure to identify root causes and take timely corrective actions.
2) The failure to conduct an adequate criticality safety evaluation for the hopper and moisture dropout tanks.
3) The failure to functionally verify that the installed safety controls match the design documents.
4) The failure io update criticality safety evaluations to assure that all assumptions are justified, documented and independently reviewed.

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5) The failure to control criticality safety evaluations in accordance with a management control program for licensed activity records.
6) The failure to make appropriate 4-hour notifications to the NRC Operations Center.
7) The failure to develop or implement NCS precedures and policies.

The licensee was in basic agreement with two of the three examples identified in Violation 01; general;f agreed with Violations 02,03, Ot, & 07; acknowledged certain aspects cf Violation 05; and disagreed with Violation 06. The licensee stated that it understands the seriousness of the current enforcement action, and the importance of maintaining safety at the plant and complying with NRC regulations, conditions of the license, and other NRC commitments. The licensee also noted that doub!s contingency protection existed and that this was the basis for restart. When questioned by the staff, the licensee committed to provide additionalinformation supporting the basis for restart of the pellet area ventilation system on August 26,1997.

The licensee discussed the safety significance of the events, the root cause determinations, the findings of its Regulatory Process Review Team, corrective actions taken and planned, self-identification aspects, mitigation factors and discretionary considerations. The licensee stated that, based on the NRC's Enforcement Policy (NUREG 1600), the collective violations should be no greater than Severity Level lit and that civil penalty mitigation was warranted due to:

1) Self-identification based on the extensive efforts after identifying the incidents in determining the root causes and programmatic corrective actions needed.
2) The prompt and comprehensive corrective actions.
3) Senior management attention from the highest levels of the Energy Systems' Business Unit.
4) The health and safety of the public was not compromised and double contingency existed at all times.

The meeting was adjourned.

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Attendees Westinghouse Commercial Nuclear Division J B. Allen, Columbia Plant Manager L A. Campagna, Assistant GeneralCounsel R. L Ervin W. L. Goodwin, Manager of Regulatory Affairs J. W. Heath, Manager of Regulatory Engineering cnd Operations R. A. Williams, Advisory Engineer Regulatory Affairs NflC E. W. Brach, Deputy Director, Fuel Cycle Safety and Safeguards J. Davis, Nuclear Process Engineer, Operations Branch C. Gaskin, Project Manager, Licensing Branch P. Harich, inspection Assistant, Operations Branch P. S. Lee, Fire Protection Engineer, Operations Branch N. Mamish, Office of Enforcement W. Schwink, Chief, inspection Section G. Smith, Chemical Engineer, Operations Branch E. Q. Ten Eyck, Director, Fuel Cycle Safety and Safeguards P. Ting, Chief, Operations Branch W. M. Troskoski, Sr. Chemical Engineer, Operations Branch M. F. Weber, Chief, Licensing Branch D. L. Wha!ay, Physical Scientist, Operations Branch h '.,

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Enclosure 2

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4 PREDECISIONAL ENFORCEMENT CONFERENCE AGENDA WESTINGHOUSE ELECTRIC CORPORATION COMMERCIAL HUCLEAR FUEL DIVISION October 29,1997 at 1:00 pm NRC Headquarters, Rockville, Maryland

l. OPENING REMARK 8 AND INTRODUCTION Elizabeth Q. Ten Eyck, Director .

Division of Fuel Cycle Safety and Safeguards, NM98 II. NRC ENFORCEMENT POLICY Neder Mamish, Office of Enforcement lli.

SUMMARY

OF THE MATTER Phil Ting, Chief Fuel Cycle Operations Branch IV. LICENSEE PRESENTATION Jack Allen, Plant Manager Westinghouse Columbia Fuel Fabrication Facility V. BREAKINRC CAUCUS VI. NRC FOLLOWUP QUESTIONS Vll. CLOSING REMARKS Ellaabeth Q. Ten Eyck, Director Division of Fuel Cycle Safety and Safeguards, NMSS

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APPARENT VIOLATIONS THE FOLLOWING IS A

SUMMARY

OF THE POTENTIAL VIOLATIONS THAT WERE PROVIDED IN GREATER DETAllIN THE EXECUTIVE

SUMMARY

SECTIOL OF INSPECTION REPORT 97 205. ,

I. INADEQUATE INCIDENT INVESTIGATION OF BOTH EVENTS, INCLUDING FAILURE TO IDENTIFY ROOT CAUSES AND TAKE TIMELY CORRECTIVE ACTION, ll. FAILUR'2 TO CONDUCT ADEQUATE CRITICAll1Y SA'FETY EVALUATIONS FOR THE GRANULATOR HOPPER AND MOISTURE DROPOUT TANKS.

Ill. FAILURE TO FUNCTIONALLY VERIFY THAT INSTALLED SAi!ETY CONTROLS MATCH THE DESIGN DOCUMENTS.

IV. FAILURE TO UPDATE CRITICALITY SAFETY EVALUATIONS TO ASSURE THAT ALL ASSUMPTIONS ARE JUSTIFIED, DOCUMENTED AND INDEPENDENTLY REVIEWED.

V. FAILURE TO CONTROL CRITICALITY SAFETY EVAll'AflONS IN ACCORDANCE WITH A MANAGEMENT CONTROL PHOGRAM FOR LICENSED ACTIVITY RECORDS.

VI. FAILURE TO MAKE APPROPRIATE 4 HOUR NOTIFICATIONS TO THE NRC OPERATION 8 CENTER.

Vll. FAILURE TO DEVELOP OR IMPLEMENT NCS PROCEDURES AND POLICIES .

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q WESTINGHOUSEELECTRIC CORPORATION COMMERCIAL NUCLEARFUEL DIVISION COLUMBIA, SC FUEL FABRICA TION FA CILITY '

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PRESENTATION TO THE U. S. NUCLL. iR REGULA TORY COMMISSION PREDECISIONAL ENFORCEMENT CONFERENCE

! REGARDING NRCINSPECTIONREPORTNO. 70-1151/97-205 l

l October 29,1997 i

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toryRemarks J. B. Allen SigniEcanceofEvents _WCFFFPlantMgr.

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W e to NRC's Findings ofApparent Violatimss l

use Determinations l toryProcessReview Team Findings

'veandENective CosrectiveActions Self-identiHcationAspects

{ tion Factors and Discretionary Considerations  ;

I SummaryandConclusions i  !

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TRODUCTORYREMARKS c

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i l Westinghouse Electric Corporation @ Is Hers to Discuss Our

\ Actions in Response to incidents involving Loss of Volume Controlfora PeHet Line GranulatorHopperand the PelletArea Ventilation System Moisture Dropout Tanks, and the Apparent Violations Resulting From the NRC Staff's inspection ofthese Twoincidents.

a NRCIRNo. 70-1151/97-205 Documents the NRC's Current

, Perspective ofthe Two incidents andSeven Apparent Violations, Which We WiHAddress.

n Our Overall Understanding ofthe incidents, including Their

. SafetySigniHcance, OurResponse to the Apparent Violations, Ourinvestigations, Root Cause Determinations and Corrective

Actions Are Addressedin OurPresentation.

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ODUCTORYREMARKS

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m }s,< Qs Ji.f , First, to Place the Two incidents in ProperPerspective, Double

- Contingency Protection Existed, f_n Reality. at All Times at CFFF: '

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  • Thatis: AtAll Times, Safety was Assuredin That Criticality Couki NotOccurWithoutatleast TwoIndependent, Concurrent Unlikely l Procass Upsets.  :

a W Understands the Seriousness ofthe Current Enforcement Action and the importance ofMaintaining Safety at CFFF, and Complying with NRC Regulations, Conditions ofOur License, t andOurCommibnents to the NRC.

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-a UCTORYREMARKS l Regarding the Incidents, _WAlso Understands: _

i The Need to Ensure That As-Built orInstalled Geometry and Volume Criticality Safety Controls Used at CFFFMatch the Assumptions in Our Design Documents, including Required VeriHcations and Updates.

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  • Management's OverallResponsibilityibrCompliance with CFFF l NuclearCriticalitySafetyLicense Conditionsand Applicable
RegulatoryRequirements.

Our Obligation to Promptly Notify the NRC - in Accordance with Our License Commitments - when a NotiWable Incident Occurs, and to PromptlyInvestigate and Take Comprehensive andEffective Corrective Actions in Response to Allincidents, WhetherNotiMable or l Not i

l The NeedforStrengthening andMaintaining Active Management Oversightandinvolvementin CFFFRegulatoryProcess Compliance, Especiallyin the Area ofNuclear Criticality Safety Processes.

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1 UCTORYREMARKS

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in Response to the Two incidents, WCFFFHas: ,

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Formed a RegulatoryProcess Review Team, Facilitatedby the CFFF Plant Manager, to Review Regulatory Processes at CFFF, with Initial Focus on the Nuclear Criticality Safety Regulatory Process;

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i Undertaken Investigations and Performed Structured Root Cause Analyses ofthe Twoincidents;and Implemented Comprehensive Corrective Actions to Address the '

Specific Incide:sts andApparent Violations, and to Prevent l ProgrammaticRecurrence.

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UCTORYREMARKS .

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! WRemains StronglyCommittedto:

The Health & Safety ofthe Public and CFFFEmployees Protection ofthe Environment TotalQualityManagement l

  • Compliance with NRCRegulatoryRequirements, License Conditions l andOurCommibnentsMade to theNRC Active Management Oversight and ControlConcerning AllAspects of l CFFFOperations i

Open Communications with NRCStaff; including:

- RequiredincidentNotiHcationsandSafotyReports

- TimelyCommunication ofOtherRelevant/ Appropriate issues.

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!YSIGNIFICANCEOFEVENTS .

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\ At No Time Was Health or Safety Compromised for the Public, l CFFFEmployees orthe Environment

! i Despite the Occurmnce ofthe Two incidents and DeSciencies in l Criticality Safety Evaluations (CSEs), Double Contingency Protection Did, Ln Reality. ExistAtAll Times. i t '

I a The Incidents and Subsequent Investigations and Management l Evaluations Did, However, Identify Certain Aspects ofthe CFFF l Nuclear Criticality Safety Program Which Could, ifNot l

I Corrected, Have a Potentialfor Safety SigniHcance in the Future.

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' .=' s SPONSE TONRC'SFINDINGSOF RENT VIOLATIONS NRCInspection ReportNo. 70-1151/97-205, Dated October 2, 1997, Documents the NRC's Findings ofSeven Apparent Violations, SummarizedAsFollows:

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l 1. InadequateincidentInvestigations

2. Failure to ConductAdequate Criticality Safety Evalu.ations (CSE's)
3. Failure to Functionally Verify That Safety-Significant Controls Were l Installed to Match Design Safety Criteria l 4. Failure to Update CSEs to Assure AllAssump!1ons Are JustiRed, l Documented, andindependentlyReviewed S. Failure to Maintain and ControlNuclear Criticality Safety Records r in Accordance with Written Procedures
6. Failure to Provide 4-HourNotification to the NRC Operations Canter
7. Failure to Develop orImplement Nuclear Criticality Safety Policies andProcedures Thatidentify Requirements forimplementation of l

NRCRegulationsand License Conditions.

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I SPONSE TO NRC'SFINDINGS OF RENT VIOLATIONS

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WAcknowledges Certain Aspects of the NRC's Statement of I

Apparent Violation That the initial Root Cause incident l ~ ~

Investigation and the Initial Corrective Actions for the Granulator l HopperLoss ofMass Contingency Were Not Adequately l Implemented (Apparent Violation 97-205-01a & b)in That:

The CFFFIncidentReviewCanmitteeDidNotReactBeyondthe

Operational Aspects ofthe incident; and i

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  • In-Depth Correc6wr Actions, Not Related to Re-Establishing System i Satiety, to Address Programmatic issues Were Not idenU6edand i Takenin a TirnelyManner.  ;

i a W Generahy Agrees with the NRC's Statement ofApparent l Violations Concerning the Adequacy ofthe Referenced CSE's,  ;

\ including Performing Functional Verifications and Updates (Apparent Violations 97-205-02, 03, & 04).

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TO NRC'SFINDINGS OF RENT VIOLATIONS .m - -

WAcknowledges Certain Aspects ofthe NRC's State:nent of Apparent Violadon Concerning the Adequacy ofthe Contmlof l Nuclear Critical lty Safety Records in Accordance with Written l

Pmcedures (Apparent Violation 97-205-05)in That:

l The CFFFRecords Maintenance Procedure CA-004, Although Covering Nuclear Criticality Safety Records, Did Not include l SutWciently Detailed Guidance with Respect to Such Records; snd Although Nuclear Criticality Safety Records are Maintainedper the CFFFRecords Maintenance Procedure, Enhancements are Needed to Enable Personnelto Readily Retrieve Such Records.

a WAlso Acknowledges That, As Set Forth in the NRC's Statement l

ofApparent Violation, The identiriedAspects ofApplicable NRC Regulations and CFFFLicense Conditions Were NotincludedAs l

Requirements forImplementation in Nuclear Criticality Safety Policies andProcedures (Apparent Violation 97-205-07):

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_ W Nunetheless Believes That OurNuclear Criticality SafetyPolicies andProcedures, AsImplementedby CFFFPersonnel, Are Adequata to Assure PlantSafety.

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W's IndicatedPosition on These Apparent Violations is l Confirmedby the Findings ofthe CFFFRegulatory Process I Review Team.

The Review Team's Observations andRecommendations That Have Led to the Resulting Corrective Actions Completed to Date, or ThatAre Underway or Planned, Shouldbe Consideredby the NRCinits EnforcementDecision-l l

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i SPONSE TO NRC'SFINDINGS OF RENT VIOLATIONS The NRC's Statement ofApparent Violation Concerning the Fact That_W DidNot Determine Root Causes and Take Corrective Actions for the Pellet Area Vendiation System Moisture Drop-Out Tanks Unanalyzed Condition Priorto Restart (Apparent Violation 97-205-01c)is Not .!

Appropriatein That-It is Acceptable to Conduct Root Cause Investigations and Complete Implementation ofCorrective Actions, Beyond Those (tequired to Re-l Establish System Safety, AflerRestart:

_W's Nuclear Criticality Safety Engineers Con 6rmed and Veri 6ed That the Component Couldbe OperatedSahelyin That Double Contingency Protection, J_n Reality. E>tisted. This Was the Basis tbrSystem Restatt

_Wis Not A ware ofAny Regulatory Requirement, Noris There a CFFF License Condi6on That Supports the 4pparent Violation.

- The Apparent Violation is inconsistent with Recent NRC Generic Guidance l That Allows 10 CFR Part 50 Licensees to Restart Their Plants and Continue l to Cperate UnderSafety-BasedJusti6 cations ofContinued Operation (See j Generic Letter 91-018, Rev.1, October 8,1997).

n For ClariHcation, _WNotes That it Shut Down Pellet Lines on 8/2987Due to the Intem.2tationalDifferences On This issue with the NRCInspectors.

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SPONSE TO NRC'SFINDINGS OF

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WDoes Not Concus ' with the NRC's Statement ofApparent l l Violation That it Did Not Notify the NRC Within 4-Hours of l ' ~

7 /dentifying the DeHcient CSEfor the Pellet Area Ventilation System Moisture Drop-Out Tanks (Apparent Violation 97-205-06a) l in nal-i l

  • A FormalNotiRcation UnderLicense Section 3.7.3(b.3.), Which States 4-HourNoti6 cation Be ProvidedFor: "AnyDetermina60n Thata Cri6cality Safety Analysis orEvalua6on Was DeRcient AND That Double ConUngencyProtection, f_n Fach Does NotExist," Was Not RequiredBecause_WDetermined 7 hat Double ConUngency Protection Existedin Fact
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  • WesUngoM interprets This iicense Condi6on to Mean That Both  ;

I Bements ofSection 3. 7.3(b.3.) Must Actually Exist Before a NotiRcationisRequired.

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SPONSEONNRC'SFINDINGS OF RENT VIOLATIONS l Further, the NRC's Discussion of This Apparent Violation in the Inspection ReportImproperly Refers to Bulletin 91-01 Criteria That Have Been Superseded By W's Renewed License Conditions:

l The Incident NotiRcation Commitments in Section 3. 7.3 Were l Included Only After the NRC Accepted _W's Revised Bulletin 91-01

! Response Which Stated That the Attachment Thereto Containing the Identical Commitments was in Lieu ofPrevious Bulletin 91-01 Commitments (See_W Letter, NRC-96-038, August 14,1996, NRC Letter, October 30,1996).

The NRC's Acceptance Letter SpeciRcaHyAcknowledged That ns

" August 14 Letterandits Attachment Supersedes AH Previous Commitments Made Pertaining to NRC No66 cations Made in '

l Accordance with the Bulletin." (NRCLetter, October 30,1996).

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SPONSEONNRC'SFINDINGS OF RENT VIOLATIONS t

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_WAlso Does Not Concur with the NRC's Statement ofApparent Violation That it Did Not Notify the NRC within 4-Hours of Identifying the DeScien! CSE for the Pellet Line Granulator l

i HopperIncident(Apparent Violation 97-205-06b)in That:

W. in Fact, NotiMed the NRC Pursuant to Section 3. 7.3(b.2) within 4-Hours ofthe Time That the Regulatory EngineerActually Concluded That The Double Contingency Conb nis, Documented in the System SafetyAnalysis, Were Notin Place.

n WRecognizes ThatInterpretationalDitferences Exist on the Meaning andintent ofthe Section 3. 7.3 License Condition.

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TCAUSEDETERMINATIONS

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l __ W ConductedInvestigatione andRoot Cause Analyses ofEach j incident: '

Pellet Line GranulatorHopperRoot Cause Analysis Team Established June 25, 1997: RCA Report Approved August 5, 1997.  ;

l PelletArea Ventilation System Moisture Drop-Out Tanks Root Cause

! Analysis Team EstablishedSeptember4,1997;RCA Report Approved I

October 7,1997.

i StructuredRoot Cause Analysis Methodology Employed with Trained Investigation Team in Accordance with CFFFEstablishedProcedure andProcess.

i Each Team Developeda Scenario-Tima-Line andIdentiRedSpeciHc CausalFactors andResponsiv c.iorrective Actions (Certain Elements ofthe GranulatorHopperInvestigation and Corrective Actions Were NotidentiRedandhnplementedin a TimelyFashion.)

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'OTCAUSEDETERMINATIONS 1 _ .

1 j Basedon the CombinedFindings ofthe initialinvestigations, the l CFFFIncident Review Canmittee, in Accordance with Procedure .

I RA-111, Recommended Thata RegulatoryProcess Review Team i Be Established to Examine CFFFRegulatory Processes, with InitialFocus on ths Nuclear Criticality Safety Process.

The Team was FormedBy the CFFFPlant Manageron 9/24/97.

The Team included the Regulatory Engineering and Operations .

Manager, the Acting ChemicalProcess Engineering Manager, the .

l Plant Systems Engineering Managerand Three SeniorRegulatory Affairs Engineers, and was Facilitatedby the CFFFPlantManager.

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t REGULATORYPROCESSREVIEW l MFINDINGS l The Team ConductedA Comprehensive ReviewandEvaluation of l the Effectiveness ofthe CFFF RegulatoryProcess andincluded l

in its ReviewInformation, Requirements, Conditions and Commitments Containedin:

August 1992NRCStaffOperationalSafetyAssessment, and Subsequent CFFFResponse l

  • SNM-1107 License Application / License
  • NRC StaffSalTety Evaluation Report on SNM-1107 License Application NRC Statl's Subsequent Requests forAdditionalInformation (RAl's) ,

NRC StaffInspection Reports for 1996 and 1997, and Subsequent l CFFFResponses  ;

Pellet Line Granulator Hopper Root Cause Analysis Report i Pellet Area Ventilation System Moisture Dropout Tanks Root Cause l AnalysisReport t

EA 97-244(Loss ofCurrentKnowledge ofLocadon ofFuelRods)

EnforcementConference andNOVDocumentationPackage

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History ofActive and CompletedActions ofthe CFFFSafety Margin ImprovementProgram(SM/P).

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REGULATORYPROCESSREVIEW -

MFINDINGS k

l Specific to Nuclear Criticality Safety, the Team IdentiRed l

Programmatic Root Causes Relevant to the Two incidents That Are the Subject of This Enforcement Action:

l RegulL oryEngineering Activities Were NotImplementedin a l Disciplined, TimelyandWellDocumentedMannerForCertain

\ Nuclear Criticality Safety Regulatory Program Areas (f.E.,

l Administrative and Documentation Requirements for CSEs).

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These issues Were NotidentiRedin a TimelyMannerBy the CFFFSelf AssessmentProcess.

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  • ManagementOversightandReviewActivitiesDidNotidentifyand Elevate These issues to Produce Corrective Actions on A Programmatic Basis.

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REGULA TORYPROCESSREVIEW .

1 MFINDINGS .. . .. .

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l Basedon These IdentifiedRoot Causes, the Review Team

! Concluded That There Was a Need to Teke Corrective Actions to l Address Certain Administrative and Documentation Compliance  ;

l Issues in the Following Nuclear Criticality Safety Program Areas:

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  • DesignsafetyBasis I
  • ManagementofChange Compliance QuaMtyAssurance Procedures (+ Criticality safety Handbook)

DocumentatiorWRecordkeeping i IncidentEvaluatiorWNoti6 cation

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  • Management OversightandControl i

a The Review Team Confirined ?he Comprehensiveness ofits t

i Findings Based, in Part, on the Correlation ofits Findings with NRCIRNo. 70-1151/97-205.

I a The Team Also Determined That the Nature ofthe Compliance Issues to Be Addressed Do Not Adversely Affect Plant Safety.

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(f{2W~;f}MPREHENSIVEAND

% EFFECTIVE '

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{RRECTIVEACTIONS Areas identiRedby the CFFFRegulatory Process Evaluation

, Review Team Requiring Corrective Actions Are Responsive to andAddress the Apparent Violations identiRed By the NRC. '

Corrective Actions Taken Address Both immediate and Lasting Corrective Actions and Together Constitute a Comprehensive l

Corrective Action Plan to Address These issues andPotential Nuclear Criticality Safety (NCS) Issues with Similar Root Causes.

a A Status ofOurActions to Date is Also Provided.

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L VEANDEFFECTIVE TIVEACTIONS-IMMEDIATE c:a

t Violation 97-205-01 -Inciderdinvestigations

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Procedure RA-111, " Safety SigniHcantincidentInvestigations" isBeingRevisedtoAdd:

Criteria on Timeliness ofRCA Activities andforPrioritizing Recommendations andImplemenUng Corrective Actions Guidance to RCA Teams to ConsiderManagement Controland l RegulatoryProcessesin TheirDeliberations

\

  • Requirement thatRCA Teams Be Chartered with SpeciRc Managementinstructions to Ensure ThatAllofthe PotentialRoot '

Causes Are Addressed, including the Need to Comply with License i

Condidons Guidance xtEventRecoveryandRestartAuthority.

i j n RevisedProcedure to Be ApprovedandFullyimplementedand

\

I PersonnelTrainedBy 11/15/97.

t f

t 10f2867 23 I

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L__ ... _ - _ . _ . . _ _ _ _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - _ - - - - - - - - -

I

a

  1. wwe WMPREHENSIVEANDEFFECTIVE I

'RRECTIVEACTIONS -IMMEDIA TE I - .

l rent Violation 97-205 Conduct ofAdequate Criticality l etyEvaluations:  :

t Pellet Line GranulatorHopper CSEand Pellet Ventilation System i Moisture Drop-Out Tank CSE Were Updated to Meet License l Commitments.

t a Procedure RA-104, " Regulatory Review ofConRguration Change Authorizations," Was RevisedandImplemented to Ensure:

F7 eld VeriWcations ofidenti6ed Controls, Equipment, Etc. >

j = AdequateReviewsofChanges l

Applicable Drawings to Be Signed OffAre Identi6ed During the Review Process Safety Signi6 cant Controls That Require Preventive Alaintenance Are Speci6ed During theReviewProcess

  • Applicable Saliety Signi6 cant Controls Are identi6edand Placedin Procedure ,

RA-108, "Sakty Signi6 cant Interlocks. "

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e,a - w I

IVEANDEFFECTIVE T/VEACTIONS-IMMEDIATE t Violation 97-205 Conduct ofAdequate Criticality fetyEvaluations:

Training to the RevisedProcedure Was Performed and Documented for Those Individuals involved with Reviewing Changes and to Emphasize the importance ofFollowing Procedures.

n Comprehensive Training for CFFFNuclear Criticality Engineers in the Preparation and Revision ofCSEs is in Progress and Will Be CompletedNo Later Than 11M997. l

.1 10728/97 25

m W >

~

VEANDEFFECTIVE TiVEACTIONS-IMMEDIATE

~

v:q ~

l t Violation 97-205 Conduct ofAdequate Criticality fetyEvaluations:

g  :.#*- a A Comprehensive, Facility-Wide Field-VeriHcation ofPlant

' Equipmentis On-Going to Demonstrate That the As-Exists Geometryand Volume Criticality Safety Controls Usedin the

\ FacilityMatch the Assumptions in CFFFDesign Documents.

There are Three Components of This MajorEffort:

l Field VeriScations to Compare Process Drawings andDrawing l Measurements to As-Built orinstalled Equipment and to ConHrm All l Existing Equipment is Reflected on Drawmgs.

i 3

i l

=

File VeriHcation ofSystems' Documentation to Confirm Analyses l ExistforEquipment l

Process Hazards Analyses ofPlant Ventilation Systems, Focusing on l NuclearCriticalitySafety 10r28/97 26 ,

5

L u-i VEAND EFFECTIVE TIVEACTIONS-IMMEDIATE r:;e

.s ,

" ~! g

L nt Violation 97-205 Conduct ofAdequate Criticality l -

fetyEvaluations:

l These Actions Are Being Performed on An Accelerated Basis and Are Scheduledfor Completion by 12MS/97:

  • The Status of Findings to Date ConGrms ConHdence in the CFFF PlantSaf1 ?? Margin. ,

, 1 l

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1 0 r2 8 8 7 27 i

O

g' "f"%

MMPREHENSIVEANDEFFECTIVE 1

l

__. _;RRECTIVEACTIONS-IMMEDIATE .

.;~

t Violation 97-205 Functional Verification ofSafety t Controls:

Volume ofPellet Une GranulatorHoppers andPellet Ventilation System Moisture Drop-Out Tanks Wera Field-Verified.

m Procedure RA-104, " Regulatory Review ofConHguration Change Authorizations,"RevisedandPersonnel Trained.

n Training Planned for Nuclear Crit lcality Engineers in CSE PreparaUon andRevision By 11/16797.

n Comprehensive, Plant-Wide Field Verihcation Instituted.

1CV2&97 28  ;

Amy=*ingn .

t MPREHENSIVEANDEFFECTIVE

.-~ .l (RRECTIVEACTIONS-IMMEDIATE l parent Violation 97-205 Criticality Safety Evaluation Updates:

i

Procedure RA-104, " Regulatory Review ofConfiguration Change  ;
Authorization, " Revised and Personnel Trained.

Training Planned for Nuclear Criticality Engineers in CSE Preparation and Revision By 11/1997.

a Comprehensive, Plant-Wide Field VeriWcation Instituted.

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i 1CV28/97 29 i

4

_ _ _ _ _ ___..,m - - - - . . , _ -,_.,r --...,m- -.- , -_ . -- , , ... _.m..,-__ ..,_ , . _,,,, , _ . _ ,, , - . _ _ _ , ___ . ,___.,___. _ . .. -. ,.._ , . --, _ , . , - . ,__ .,y__ . . - . . - . , .., , r,, . . , _ , , , , . . . . , , , , , , - - - . , . , - - . ,

gyr+m S&MPREHENSIVEAND EFFECTIVE 1

.1

,RRECTIVEACTIONS-IMMEDIATE J .

w: ; ,

1 parent Violation 97-205 Nuclear Criticality Safety ecords:

l l Procedure CA-004, " Columbia Plant Records Management l Policy" is Being Revisedto Enhance:

l Guidance / Requirements for the Maintenance and Control ofNuclear l CriticalitySafetyDocuments 1

l

  • Requirements for the Storage ofand Access to Nuclear Criticality l SafetyDocuments.

l i

l a Procedure to Be ApprovedandFullyimplemented andPersonnel i Trainedby 11/30/97. .

l 1

4 1

4 10/28/97 30

g a VEAND EFFECTIVE

~

TIVEACTIONS-IMMEDIATE i ;m .

l ?_? parent Violation 97-205 NatiHcation Requirements:

4 l -

Although W. Does Not Believe Thata Violation ofLicense l =- NotiRcation Requirements Occurred, Given the Differences in l Understanding Between_ Wand the NRC Regarding This issue, _W i 'Has Requested That a . Management Meeting Be Scheduled With l NMSS to Resolve This and OtherInterpretationalissues.

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kMPREHENSIVEANDEFFECTIVE

-- J

?RRECTIVEACTIONS -IMMEDIA TE parent Violation 97-205 NuclearCriticalitySafetyPolices i

d Procedures to identify Requiremerds for implementaUon ofNRC egulations andLicense Conditions:

An Extensive Review ofSecUon 6.0 ofSNM-1107 Was Performed l andApplicable Program Elements Were incorporatedinto New .

l orRevisedDraftProcedures. '

l l m AllNRC CitedProceduralDeficiencies Were Addressed Through Procedure Revisions.

! i

' n AllNewandRevisedProcedures WillBe ApprovedandFully implernented andPersonnel TrainedBy 12/31/97.  !

i a CSE Guidelines Which Are included As a Subset of"CFFF i Baseline Integrated Safety Assessment Guidelines" Were l PreparedandFormalized; the Guidelines WillBe Approvedby l 11/15/97.

i 1

l 10/28s7 32

sfjjy!Eihj f MMPREHENSIVEANDEFFECTIVE 1

.- ... . -- _. i'RRECTIVEACTIONS -IMMEDIATE

AddiUon to the Actions Taken forEach Specific Apparent l

i

'oladon, the Following Management Oversight and Control itiatives Were Completed:

! CFFFPlant Manager Directly Interfaced with Regulatory Management, and Established the Regulatory Process Review Team.

l n Regulatory Compliance issues and the importance ofRegulatory i Compliance Were Stressedat Plant Manager's AllEmployee, i

Production, StatfandRoundtable Meetings.

l n Certain of These issues Were DiscussedBy Division VP and i Columbia PlantManagerDuring RecentMeetings with Both NRC Region // and Headquarters Management i

i I 10f28/97 33

,: . n l IVEAND EFFECTIVE I

2 -

TIVEACTIONS -LASTING For Lasting Corrective Actions, We Have EstablishedNew Initiatives or Made Enhancemen!s to Exisung initiatives Under Our Safety Margin Improvement Program (SMIP) to Address the Apparent Violations andImprove the Processes to Which the Apparent Violations Relate.

l l A FinalizedPlan andSchedule forLasting Corrective Actions Will i Be CompletedBefore 12/1587.

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1W28/97 34

,2.,

4 fENSIVEAND EFFECTIVE TIVEACTIONS-LASTING parent ViofaUon 97-205-01 and 97-205 Incident vestigations and NotiRcation Requirements:

l CFFF Will Enhance the incident Management and NotiHcation l Process to Clearly DeHne Evaluation, NotiHcation and Post i

IncidentRecoveryPhases.

i l n The RCA Process WillBe Restructured to Ensure That Broader l Implications ofincident Investigations (Beyond the "On-the-l Floor" Aspects ofths incident) are Considered.

n Documentation ofthe Incident Management Process WillBe l Enhanced to ReRect the Format ofthe Emergency Plan Process.

i a CFFFIntends to Meet with the NRC Staffon incident NotiHcation i Criteriain OurLicense.

l -

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10f28/97 35

~

IVEAND EFFECTIVE T/VEACTIONS -LASTING

nt Violation 97-205-02, 03 & 04 - Conduct ofAdequate l lity SafetyEvaluation(CSE) Processes:

i To Enhance Interim Design Safety Basis ofCFFFSystems and

, Components, all CSAs and CSEs and Supporting Documentation l Were CollectedandAre Being Indexed. The Im'ormation is Being l Assessed for Compliance to License Commitments.

Where Necessary Criticality Safety Analyses (CSAs) arod Criticality l Safety Evaluations (CSEs) WillBe Upgraded to Comply with License l Commitments.

i I

a After the Design Basis Documents Are Assembledand Updated, They WillBe incorporatedinto the Integrated Safety l Assessments (ISA 's) on A System by System Basis to Establish 1

the FinalDesign SafetyBasis.

l n in AddiUon to the CFFFProcedures Currently Being Revised to Address the Change ControlProcess, A More Comprehensive i .

Review WillBe Undertaken to Enhance Management ofChange.

10728/97 36

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - . _ _ _m . , . , _ . . ..,_, _ . . . _ . , , _ _ , . , . . . . . . _ . . _ , . .--,,,,__--.,,-_-,.----_..y,- -

VEAND EFFECTIVE TIVEACTIONS-LASTING _

parent Violation 97-205 Nuclear Criticality Safety Records:

4 l In Addition to the immediate Revision to the CFFFRecords Management Procedures, including the Assembly of Design '

Basis Documents into A CentralLocation, Recordkeeping and

Document ControlPractices Will Be Further Enhanced for l PromptRetrieval.

I S

10/2887 37

_ _ , _ . , . _ , . - . , . . - . , - - . - . . . . . - . . . -....v. s. .,... .,_ _ .

f$#[~ %

MPREHENSIVEANDEFFECTIVE l

.RRECTIVEACTIONS-LASTING

~

. 1 -

7..;;:

7, parent Violation 97-205 Nuclear Criticality Safety Policies dProcedures to identify Requirements forImplementation of RC Regulations and License Conditions:

Building Upon the Review ofSection 6.0 ofSNM-1107and Incorporation ofLicense Requirements into New or Revised Procedures, Describedas Part ofOurimmediate Corrective Actions, This Process WillBe Undertaken for the Remainder of the License to Ensure License Requirements are Effectively Translatedinto Administrative and Operating Procedures. A Compliance Quality Assurance Element Will Be a Part of This Effort.

4 tar 2aar 38 g

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w* .

VEANDEFFECTIVE TIVEACTIONS -LASTING g:

t Addition to the Lasting Actions Taken/ Planned forEach Specific parent Violation, AdditionalManagement Oversightand Control itiatives Are Underway:

1 CFFFPlant Manager Will Continue to Direct the Regulatory Process Review Team a Management Oversight Tools WillBe Employedto Track Acceptable Performance to Regulatory Commitments

  • Enhanced SMIP and Commitment Tracking ofRegulatory Requirsments
  • Communications to Plant Personnel, E.G., Roundtable, Production andPlantStetfMeetings
  • Refocus ofRegulatory Compliance Committee and Use ofCorrective Action Committee Methodology.

. 10/2887 39

jgwa l .

1

  • -1FIDENTIFICA TIONASPECTS

~

l i . .

pc3 ew  :

t CFFFPersonnel Self-identified the Loss of Volume Control for the l PelletLine GranulatorHopper, andNotiRedNRCStaffofthe l Incident (an " Event"As DeHnedin the NRC's Enforcement Policy) l on 6/23/97.

\ CFFFPersonnelSelf-Identified the Loss of Volume Controlfor the

! Pellet Ventilation System Moisture Dropout Tanks, andInformed

[ NRCStaffofthe Eventon 8/28/97.

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. 10/28/97 40

_ _ _ _ _ . _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - . . _ _ _ _ _ , . _ _ _ _ _ _ . . , - . . _ , = . , . . . , - ,.-r w -

-v- - - - -

mn-L -

1F/DENTIF/CATIONASPECTS nw

.II$$75.I

~sp

?* Notwith;.ianding These Self-identiHcation Aspects, There Were Missed Opporturaities for EarlieridentiHCation ofthe Programmatic Aspects ofthe Apparent Violations:

  • CSA/CSE Update Program and Summary Submittals to NRC Were Pertbrmed withoutSuRicient Thoroughness.
  • NCS Field Veri 6 cations for CFFFSystems Modi 6 cations Were Not

?

SystematicallyPeribemed.

  • There Was InsuRFcient Programmatic Follow-Up to CFFFReviews and Responses to NRC Nuclear Criticality Sanrty inspection 96-204.
  • _wDidNot Conplete the Investigation ofand Corrective Actions for the Pellet Une GranulatorHopperincidentin a TimelyManner.
  • Issues Related to Management Oversight ofMC&A Area identi6 edin Response to NRC IR 97-203 (Loss of Current Knowledge ofLocation ofFuelRods) '

ProvidedNotico That Similarissues/ Trends CouldExistin the Nuclear CriticalitySafetyProgram.

n However, Once Both Events Were IdentiRed By CFFFPersonnel, CFFFManagement Proactively instituted Extensive Investigations andEvaluations to Respond to the Broaderimplications ofthe Events.

41

'._ 10Q887

a l TIONFACTORSAND TIONARYCONSIDERATIONS lation Severity LeveUPanalty Assessment Factors Basedon the NRC's EnforcementPolicy(NUREG-1600, As l Amended), the Collective Violations ShouldBe No Greater Than l Severity Levellli AND CivilPenalty MiUgation is Warranted

i' Self-IdentiNcation Creditis WarrantedBased On the Extensiv a Etforts l ExpendedBy CFFFManagement After identifying the incidents in l Determining Underlying Root Causes andProgrammatic Corrective l Action Needs.

\

  • Creditis Also Warranted for CFFF's Prompt and Comprehensive CorrectiveActions:

i

!1

- CFFF UpperManagement /mmediately Responded When NotiRed

! By Appointing Investigatory Teams to Ensure Effective Invesugations, Progremmatic Root Cause Determinadons and Comprehensive Corrective Actions.

- Immediate andLasting Comprehensive Corrective Actions Have i Been Taken orAre Underway to PreventRecurrence ofthe incidents andthe Occurrence ofIncidents That CouldHave SimilarRoot Causes.

1W2887 42

, ,. .._ , , - . . . . - - --, - - - - - - - - - - - - ~. - -------~ ~* ~ ~ '---' ~ ' ' * ' ' ' ' ' ' ' ~ * ~ ~ ' ~

y~s TflGATIONFACTORSAND

]CRETIONARYCONSIDERATIONS Ij(

e Use ofEnforcement Discretionis A ro riste The incidents Received Attention at the Highest Levels ofESBU (Energy Systems Business Unit) Management.

The Violations Although SigniHcant From a Regulatory '

Compliance Perspective, At No Time Compromisedthe Health or Safety ofthe Public, CFFFEmployees or the Environment; and Double Contingency Protection Existed At All Times.

n CFFFis A Safe Plant and Currently Has in Place Effective Safety Programs and Processes that Should Be Considered When Assessing the Violations. Agencies, including the NRC, Have l

Endorsed the IndustrialHygiene, Safety, Environmental Protection, Chemicaland Fire Safety Programs.

t

, 43 10/28/97

Ac#"

l; *BflGATIONFACTORSAND

' 3CRETIONARYCONSIDERATIONS t

> nn

! .4;;:3i e Use ofEnforcementDiscretionis A ro riate There Are Multi-Level, Proven Operational Conduct and l Management ControlProcesses at CFFFto Ensure That Non-i Compliances are Identified and Resolvedin a Prompt, EtTective andSafety-Conscious Manner. Recognized Tools Supporting These Processes are "RedBook"forProcess Upsets, Process Hazards Analysis, Root Cause Analysis, Commitment Tracking l

and the Safety Margin improvement Program.

n _WHas CommittedSignificantResourcesandis Taking l ,

Comprehensive andEffective Corrective Actions to Prevent l Recurrence ofthe Specific Apparent Violations and Similar l Incidents.

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i RYAND CONCLUSIONS l, n:? At No Time Was Safety Compromisedfor the Public, CFFF

Employees orthe Environment.

The Speci6c Apparent Violations and Their Significance to the l CFFFNuclear Criticality Safety Process Have Been Treated Very l Seriously and Appropriate Management Oversight Has Been

! Taken, and Will Continue, to Prevent Recurrence.

i

! n _W is Responding, in a Fulland Comprehensive Manner, to the

\ NRCs Apparent Violations and the Findings ofthe CFFF

RegulatoryProcess Review Team.

I i

! a _W's Comprehensive immediate andLasting Correction Actions, l and the OtherFacts and Circumstances That We Have Presented l Today, Support Consideration For the Use of Discretion By the l NRCin Making Violation Severity Leveland CivilPenalty i

Assessment Determinations.

i l 'A 10f28N7 45 l f. 8

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