ML20202J100
| ML20202J100 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 01/29/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20202J077 | List: |
| References | |
| 70-1113-99-02, 70-1113-99-2, NUDOCS 9902090038 | |
| Download: ML20202J100 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION 11 Docket No.:
70-1113 License No.:
SNM-1097 Report No.:
70 1113/99-02 Licensee:
General Electric Company.
. Wilmington, NC '28402
. Facility Name:
Nuclear Energy Production Dates:
January 4-8,1999 Inspectors:
D. Ayres, Senior Fuel Facility inspector D. Seymour, Senior Fuel Facility inspector
' Approved by:
E. J. McAlpine, Chief Fuel Facilities Branch
' Division of Nuclear Materials Safety Enclosure
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EXECUTIVE
SUMMARY
General Electric Nuclear Energy NRC Inspection Report 70-1113/99-02 The primary focus of this routine unannounced inspection was the evaluation of the licensee's conduct of plant operations, training, and environmental protection programs. The report covered a one week period and included the results of inspection efforts of two regional fuel facility inspectors.
Plant Operations The licensee's evaluation of and corrective actions for two criticality safety events were adequate to prevent recurrence (Section 2.a(2)).
The management-levelinvestigation for the release of contaminated component to an off-site machine shop was adequately completed (Section 2.b(2)).
The licensee's Year 2000 readiness plans were aggressive and adequately provided contingencies for potential problem areas (Section 2.b.(2)).
Environmental Protection l
The licensee's contractor developed a Work Plan that adequately implemented the NRC-approved Calcium Fluoride (CaF ) Area Survey and Release Plan. Workers 2
involved in the soil sampling operation were adequately trained and supervised (Section 3).
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Trainina General employee safety training adequately covered the topics required for helping e
protect workers from radiological hazards (Section 4).
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REPORT DETAILS i
1.
Summarv of Plant Status This report covered the efforts of two regionalinspectors for a one week period. Soil sampling for final release of the old CaF, storage pit area in the northwest portion of the plant site was underway. Portions of the integrated gadolinium shop were shut down to implement process improvements. Pellet proouction, rod loading, bundle assembly, and uranium recovery continued operations at normal levels. There were no unusual plant operational occurrences reported during the onsite inspection.
2.
Plant Ooerations (03) (IP 88020) a.
_R_eview of Previous Events (O3.07)
(1)
Inspection Scope The internal investigation results for two previous events were reviewed
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to determine the adequacy of the licensee's actions.
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i (2)
Observations and Findings l
Event Notice No. 34562: Unauthorized Transfer of Liauids The inspectors reviewed the root cause evaluation surrounding Event Notice No. 34562 concerning the transfer of liquids to the V-108 fluoride waste treatment vesselin excess of the allowed uranium concentration.
The inspectors observed that the event occurred during shutdown operations in preparation for the annual Special Nuclear Material (SNM) inventory. During normal operation, transfers of fluoride waste were made to the V-108 vessel after passing through an ion exchange media and an in-line radioactivity detector. During inventory shutdown preparations, the ion exchange media was back-flushed to remove most of the uranium. The back-flush liquid was collected in vessel V-106 upstream from the ion exchange system. The back-flush was then routed to V-108 through a temporary line while bypassing the ion exchange media and in-line radioactivity detector. The back-flush liquid was sampled prior to transferring to V-108. Monitoring the uranium concentration of liquids entering vessel V-108 during inventory shutdown preparations was also to be performed through analysis of hourly samples.
The back-flush liquid exceeded the uranium concentration limit of 25 parts per million (ppm) for vessel V-108. However, the operators performing the transfer of liquid to V 108 did not recognize that this exceeded the V-108 concentration limit. Instead, the operator mistakt.nly used the higher concentration limit for vessel V-106 to make the transfer to vessel V-108. The inspectors observed that the event was caused by
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l failure of the operator to follow the inventory shutdown procedure. Since the inventory shutdown procedure is only used once per year, a pre-job briefing of the work to be performed could have prevented the event.
Also, bypassing of the in-line radioactivity detector during inventory shutdown work shifted criticality safety controls for V-108 from an active engineered control (an automatic in-line detector) to an administrative control (a procedural requirement to check the concentration). Since administrative controls are generally considered more susceptible to human error, such a shift tended to weaken the reliability of the criticality controls for V-108.
The licensee's investigation addressed these issues and recommended corrective actions to prevent recurrence of this event. The corrective actions taken included a procedure for conducting pre-shutdown planning meetings to review the requirements associated with infrequently performed tasks. The corrective actions also included an engineered change such that the ion exchange system could be bypassed without bypassing the in-line radioactivity detectors. The inspectors found that
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these corrective actions were adequate to prevent the recurrence of this event. The transfer of liquids above the allowed concentration limits was I
a violation of NRC requirements. This non-repetitive, licensee-identified and corrected violation is being treated as a non-cited violation (NCV 99-02-01), consistent with Section Vll.B.1 of the NRC Enforcement i
Policy.
Event Notice No. 34858: Rotary Stuaaer Press The inspectors reviewed the root cause evaluation surrounding Event Notice No. 34858, concerning the loss of geometry control on a rotary slugger press. On September 30,1998, the licensee discovered approximately 20 kilograms of 4.4 percent enriched Uranium Dioxide
- (UO ) powder bridged across a hollow section of the equipment used for 2
lubrication. This part of the slugger press had not been previously analyzed for criticality safety, so this event was considered a loss of double contingency. The criticality safety analysis had assumed that any material entering the hollow section would fall into a lubricant sump.
Criticality safety in the lubricant sump was assured by limiting the geometry and mass to a four-inch slab of UO in the bottom of the sump.
2 Thus, the material found outside of the modeled four inch slab constituted a loss of geometry control.
Several factors contributed to this event. On September 16,1998, the tooling at one of the sixteen dies in the slugger failed. Spare parts were not available, and the licensee technical representative decided to remove the failed parts, use a rubber stopper to plug the hole created, and continue running the slugger. Using such a plug had been a common practice in the past. The licensee's change management procedure, which would have required review by a nuclear safety engineer, was no? implemented for this substitution. The existing
3 criticality safety analysis did not include running the slugger with tooling
. removed. The licensee concluded that, if the change management process had been implemented, this modification (running the slugger
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with a rubber plug in place) might not have been allowed, a s the event might have been avoided.
Subsequent maintenance on the slugger on September 28,1998, resulted in tooling placement errors. The rubber plug was moved to a nw (erroneous) location on the slugger, creating an open path for the powder to collect in the hollow section above the rubricant sump. _ This was discovered by the licensee on September 30, after approximately two d.ifts of slugger operation. The inspectors noted that the discovery J
of the powder in the hollow section on September 30 was a result of in-depth questioning of slugger conditions by the licensee. As a result of the discovery, the slugger was shut down and a root cause investigation
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started.
The inspectors reviewed the licensee's root cause investigation and their corrective actions for this event, and determined they were
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thorough and complete. The licensee's corrective actions included i
revising the procedure to not allow the use of nonstandard tooling,
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operator training, spare part controls, change management training, and equipment modifications based on a safety analysis of the previously unanalyzed hollow section of the slugger press. The inspectors j
concluded that the corrective actions would prevent recurrence of the i
event. However, the inspectors identified the failure of the licensee to implement their change control procedures, as noted above, as a i
violation. This non-repetitive, licensee-identified and enrrected violation is being treated as a non-cited violation (NCV 99-02-02), consistent with Section Vll.B.1 of the NRC Enforcement Policy.
(3)
Conclusions The licensee's evaluation of and corrective acticas for two criticality safety events were adequate to prevent recurrence.
b.
Follow-uo on Previous!v identified issues (O3.08) flP 92701)
(1)
Inspection Scope Follow-up actions to issues idcntified in previous inspection Report 70-1113/98-01 and in NRC Generic Letter 98-03,"NMSS Licensees' and Certificate Molders' Year 2000 Readiness Programs," were reviewed for completion and adequacy.
(2)
Observations and Findings The inspectors reviewed the licensee's actions in response to an incident where a contaminated component was released to an off site
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4 maintenance shop without the required surveys being performed. This incident was being tracked by NRC as inspector Follow-up item (IFI) 98-01-04. This incident was previously discussed in NRC Inspection Reports 70-1113/98-01 and 70-1113/98-02. The remaining issue being tracked was a critique to be performed by the Area Manager. The inspectors reviewed the final critique and fou..
- it to be of adequate
. scope and depth to ensure that the original investigation into the incident was thorough enough to prevent recurrence. Thus, IFl 98-01-04 can be considered closed.
The inspectors reviewed the licensee's second response to NRC Gt,neric Letter 98-03, dated June 22,1998, concerning identifying and addressing Year 2000 (Y2K) readiness is ues. In the response, the licensee had identified six areas of focus for aardware or software upgrades. The inspectors reviewed the scope W.ne upgrades needed in each area and i
the contingency plans for operation if the upgrades were not completed before the end of 1999 or were found to be inadequate. The licensee and its Y2K compatibility consultant indicated that the likelihood of having to implement one of the contingency plans was very low. The licensee also indicated that full Y2K readiness was expected in June 1999. The l
inspectors found that the most significant upgrac'es were in the Material Control and Accounting of Uranium functional area. The inspectors found that the licensee had an overall aggressive program for ensuring Y2K readiness and adequate contingency plans in place to implement if 4
needed.
(3)
Conclusions The management-level investigation for the release of contaminated component to an off-site machine shop was adequately completed.
Inspector Follow-up item 98-01-04 was closed. The licensee's Year 2000
. readiness plans were aggressive and adequately provided contingencies for potential problem areas.
3.
Environmental Protection (R2)
Decommissionina ActivWes (R2.07) (IP 88104) a.
Inspection Scope The sampling of the Northwest CaF, Storage Area for final releue was reviewed to ensure that the methods used adequately corresponded to the NRC-approved Survey and Release Plan.
I b.
Observations and Findings The inspectors reviewed the Final Status Survey Work Plan prepared by the licensee contractor that was performing the work. The inspectors compared the j-Work Plan with the NRC-approved CaF, Area Survey and Release Plan. The 4
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5 inspectors found that, except for a few minor deficiencies in documentation for 4
protective equipment requirements and general worker training, the Work Plan adequately implemented the requirements of the Survey and Release Plan.
1 The inspectors observed the sampling of soil from the periphery of the Northwest i
CaF Storage Area. Tha inspectors found that the workers performing the sampling were well trained in the safety requirements and sampling techniques.
This helped to assure that reasonably representative samples were taken in a safe and effective manner. The inspectors also found that the workers were adequately supervised such that unexpected problems could be handled quickly and safely.
The inspectors o'bserved that the samples were being sent to an independent laboratory for analysis. The inspectors requested and obtained ten (10) split samples that were from various locations around the periphery of the affected area. These samples were sent to a U.S. government-owned laboratory for a comparative s,nalysis. The reporting of the results of the NRC split samples along with the results of the licensee's samples will be tracked as IFl 99-02 03.
c.
Conclusions The licensee's contractor developed a Work Plan that adequately implemented the NRC-approved CaF, Area Survey and Release Plan. Workers involved in the soil sampling operation were adequately trained and supervised. Split samples were obtained by NRC for comparative analysis. The reporting of split sample results will be tracked as IFl 99-02-03.
4.
Trainina (F2) (IP 88010)
General Nuclear Criticality Safety Trainina (F2.02). General Radioloaical Safety Trainina (F2.03), and General Emeraency Trainina (F2.04) a.
Inspection Scope General employee safety training was reviewed for adequacy.
b.
Observations and Findings The inspectors observed the training videos for general site-wide safety and controlled area safety. The inspectors observed that the videos adequately covered the required basic topics in nuclear criticality safety, radiological safety, and emergency procedures. The inspectors found that the presentations were made using techniques to keep viewers attentive. The inspectors reviewed the written test and found that the questions asked were pertinent to safety and were addressed in the videos.
c.
Conclusions General employee safety tvining adequately covered thc topics required for helping protect workers ' rom adiological hazards.
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Exit Meetina On January 8,1999, the inspection scope and results were summarized with licensee representatives. The inspectors discussed, in detail, the routine program areas inspected, and the findings, including the potential licensee-identified violations for loss of criticality safety controls. No dissenting comments were expressed by the licensee.
l The licensee identified materials provided during the inspection as proprietary, although proprietary information is not contained in this report.
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ATTACHMENT l
PARTIAL LIST OF PERSONS CONTACTED L
Licensee Personnel
- M. Barringer, NFS Safety Manager l
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, D. Brown, Team Leader, Environmental Programs D. Davison, NFS Environmental Consultant.
- R. Folock, Senior Licensing Specialist M. Green, GE Y2K Consultant
- J. Kline, Manager, GENE PrW*m
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- S. Murray, Manager, Regulatory Compliance j
- L. Paulson, Manager, Nuclear Safety
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J. Pierce, Engineer, Fuel Fabrication
- C. Vaughan, Acting Manager, Facility Licensing Other licensee employees contacted included engineers, technicians, production staff, security, and office personnel.
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- Denotes those present at the exit meeting on January 8,1999.
INSPECTION PROCEDURES USED lP 88010 -
Operator Training / Retraining IP 88020
. Plant Operations
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l IP 88104 De<<c.imissioning Inspection Procedure For Fuel Cycle Facilities lP 92701 '
Followup i
L LIST OF ITEMS OPENED, ' OSED, AND DISCUSSED QD10.td 70-1113/99-02-03 IFl
. Review analyses of split samples from Northwest CaF, Storage Area decommissioning survey.
i Closed
> 70-1113/98-01-04 lFI Review results of higher level critique for release of contaminated equipment.
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-70 1113/99-02-01 NCV Failure to follow operating procedure leading to transfer of liquids above the allowed uranium concentration.
'70-1113/99-02-02 NCV Failure to implement configuration management procedure contributing to loss of geometry control and a reportable criticality
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event.
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.2 ACRONYMS
- CaF, Calcium Fluoride GENE General Electric Nuclear Energy IFl Inspector Follow-up Item IP inspection Procedure NCV Non-Cited Violation NRC Nuclear Regulatory Commission ppm Part Per Million SNM Special Nuclear Material UO, Uranium Dioxide Y2K Year 2000 A
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